Exhibit 1 Exhibit 1
The World – Coos Bay http://theworldlink.com/news/local/govt-and-politics/jordan-cove-parent-company-looks-at- financing-ownership-options-expansion/article_5fe9f9ec-b521-11e3-9421-001a4bcf887a.html MONEY STARTS FLOWING Jordan Cove parent company looks at financing, ownership options, expansion March 28, 2014 1:00 pm • By Chelsea Davis, The World COOS BAY — Now that the Jordan Cove Energy Project has federal approval to export liquefied natural gas to non-Free Trade Agreement countries, parent company Veresen Inc. is making moves financially.
Don Althoff, Veresen’s president and CEO, spoke with confidence during a conference call following the U.S. Department of Energy’s Monday announcement.
―I don’t think this is going to be a problem to finance,‖ he said of the $7.7 billion project (approximately $1.1 billion of which is project financing, owner’s cost and interest incurred during the four-year construction period). Before Veresen can make a ―final investment decision‖ in early 2015, it needs an Engineering, Procurement and Construction contract, all off-take contracts ―signed with credit-worthy counterparties,‖ and Federal Energy Regulatory Commission approval. Veresen looks for potential owners, partners
Althoff wants Jordan Cove to be ―completely sold out‖ by October or November. That means Veresen is analyzing "optimal ownership" and possibly bringing in partners. ―What we’re going to decide over the next nine months is how much we want to own of the plant, and then how much more equity do I need to raise?‖ Althoff told The World this week. Today, Veresen owns 100 percent of Jordan Cove, including the proposed marine facility, liquefaction plants, storage tanks, gas treating facilities and South Dunes Power Plant. The LNG facility will run capital costs of $5.3 billion, Veresen estimates. The Pacific Connector Gas Pipeline, which would feed natural gas to Jordan Cove through a 232-mile, 36-inch pipeline from Malin, will incur capital costs of $1.5 billion. Veresen owns half of the pipeline; the other half is owned by Williams Companies, a U.S. natural gas processing and transportation company.
―I think owning 100 percent of it ... there probably aren’t very many options where that makes the most sense for us,‖ Althoff said. Jordan Cove’s potential customers have expressed interest in taking equity positions in the facility. ―Buyers of the natural gas like to invest in these, as well,‖ he said. ―If we do bring partners on, they would pay us for our percentage of the plant we’ll sell them, then we’ll use that equity to fund the rest of our equity, then go to the market and raise it if we still need more.‖
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Time to pay the bills
Right now, Veresen just needs to pay its bills until Jordan Cove gets the go-ahead or the ax. That's why Veresen announced Tuesday it had entered into an agreement with a syndicate of underwriters who agreed to purchase 15 million shares of Veresen at $16.50 CAD ($14.85 USD) a piece to raise $247.5 million CAD (more than $220 million USD).
The underwriters also get an overallotment option to purchase up to an additional 2.25 million shares. That would bring the total closer to $284.6 million CAD ($250 million USD.) The offering will close around April 3. Veresen’s common shares are listed on the Toronto Stock Exchange under the symbol VSN.
―We still have a lot of money to spend to get (Jordan Cove) sanctioned,‖ Althoff said. ―Part of what (the $284.6 million is) used for is to pay bills between now and this time next year when we come in and finance the project.‖ Once those bills are paid, Veresen can raise more equity to pay for the bulk of the project. ―While financing won’t be without its challenges, we will have the benefit of falling on the path paved for us by other recent LNG export developments in the U.S. Gulf Coast,‖ he said. Non-FTA approval a big win for Veresen
In Veresen’s 2013 fourth quarter and year-end results report issued earlier this month, officials confirmed they were really gunning for DOE’s non-FTA export approval.
Most of Jordan Cove’s potential customers do not have FTAs with the U.S., Althoff said. Singapore and Korea are the only two east Asian countries with FTAs, and their markets are small relative to the overall market, he said.
Last fall, Veresen announced it had snagged three non-binding long-term Heads of Agreement with companies in Indonesia, India and an ―eastern Asian country.‖
Japan is the world’s largest LNG consumer, according to Thomson Reuters, but China is right on its heels — ―...it looks like China will be a top LNG importer by 2018-20.‖
Since October, Althoff said Veresen has entered into other HOAs with ―large-scale prospective customers, including various emerging and traditional LNG buyers throughout the Asia-Pacific region.‖ Veresen plans to wrap up binding Liquefaction Tolling Service Agreements and Pipeline Service Agreements by this fall. ―This is a world-scale plant,‖ he said. ―To try to think about selling to just FTA countries limited us too much.‖
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Already looking at expansion
Jordan Cove’s proposed initial LNG capacity — 6 million metric tons per year — also has its limits, Althoff said. The total amount of LNG capacity requested under Veresen’s various HOAs exceeds that 6 million. If and when Jordan Cove begins construction, Althoff said Veresen will immediately look into expanding the facility’s capacity to 9 million metric tons per year. ―The marina, tankage, gas treating and power plant can all manage 9 tonnes per annum (metric tons per year),‖ he said. ―What’s needed to expand the plant is more pressure on the pipeline and more trains. It does have the ability to expand. ―I think as soon as I can get this thing through FID (final investment decision) we will start to look at expansion projects down there.‖ FERC timeline possibly pushed back
That’s only if FERC green lights Jordan Cove. Veresen and Jordan Cove both forecasted a FERC ruling by the end of the year, with construction starting in the first quarter of 2015.
But that could be delayed. During a routine conference call between federal agencies last week, officials said Jordan Cove is changing its proposed wetland mitigation sites, meaning all of the land use tables in FERC’s draft Environmental Impact Statement will be affected. In turn, that’s going to delay FERC’s schedule while they analyze the new edits.
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Exhibit 2
UNITED STATES OF AMERICA DEPARTMENTOF ENERGY
Jordan Cove Energy Project, L.P. ) FE Docket No. 12–32–LNG ) Application for Certificate ) Jordan Cove Energy Project, L.P.; ) Application for Long-Term ) Authorization to Export Liquefied ) Natural Gas Produced From Domestic ) and Canadian Natural Gas Resources ) to Non-Free Trade Agreement ) Countries for a 25-Year Period ) ______)
CITIZENS AGAINST LNG, Inc; CITIZENS AGAINST LNG NOTICE OF INTERVENTION, PROTEST AND COMMENTS
On June 6, 2012, the Office of Fossil Energy at the Department of Energy posted in the Federal Register a Notice of receipt of an application (Application), filed on March 23, 2012, by Jordan Cove Energy Project, L.P. (Jordan Cove), requesting long-term, multi-contract authorization to export as liquefied natural gas (LNG) both natural gas produced domestically in the United States and natural gas produced in Canada and imported into the United States, in an amount up to the equivalent of 292 billion cubic feet (Bcf) of natural gas per year, 0.8 Bcf per day (Bcf/d), over a 25-year period, commencing on the earlier of the date of first export or seven years from the date the requested authorization is granted. The LNG would be exported from the proposed LNG terminal to be located on the North Spit of Coos Bay in Coos County, Oregon, to any country (1) with which the United States does not have a free trade agreement (FTA) requiring national treatment for trade in natural gas, (2) which has developed or in the future develops the capacity to import LNG via ocean-going carrier, and (3) with which trade is not prohibited by U.S. law or policy. Jordan Cove is requesting this authorization to export LNG both on its own behalf and as agent for other parties who hold title to the LNG at the point of export. The Application was filed under section 3 of the Natural Gas Act (NGA).
Citizens Against LNG is a grassroots organization of citizens that formed during the Federal Energy Regulatory Commission Prefiling phase of the Jordan Cove Energy Project, L.P. and the Pacific Connector Gas Pipeline, L.P., LNG Import project. We represent over 4,000 citizens in Southern Oregon who live, work, have businesses, recreate and socialize in areas that would be negatively impacted by the Jordan Cove LNG terminal, storage tanks, liquefaction facility and the Pacific Connector Gas Pipeline.
Citizens Against LNG, and the citizens who support our cause, declare that a liquefied natural gas (LNG) export terminal, storage tanks and liquefaction facility is not a well conceived or appropriate industry for the Southern Oregon Coast and that LNG represents an unacceptable risk to the people of the State of Oregon. For the safety, security, and well being of the citizens of our communities, the Citizens Against LNG ask the U. S. Department of Energy to immediately take action to stop the Jordan Cove LNG Export terminal, storage tanks and liquefaction facility proposed for the North Spit of Coos Bay and the 230 mile, 36 inch Pacific Connector natural gas pipeline to the California border. We ask the U. S. Department of 1
Energy to not approve the Jordan Cove Energy Project’s application to Export LNG to non-free trade agreement nations as this would not be in the best interest of the public at large. Further details as to our reasons for this are spelled out in the attached comment letter and exhibits.
In order to protect the interest of citizens in Southern Oregon, Citizens Against LNG, Inc, also known as Citizens Against LNG, moves to intervene in this proceeding, pursuant to 10 C.F.R. § 590.303(b).
The Citizens Against LNG previously petitioned, intervened and was part of a coalition of groups that filed a Request for Rehearing to the Federal Energy Regulatory Commission (FERC) concerning their Environmental Impact Statement and their December 17, 2009, Order on the Jordan Cove LNG Terminal and Pacific Connector gas pipeline project. We also petitioned the FERC to protect Coos, Douglas, Jackson, and Klamath Counties and the State of Oregon by taking action to stop the Jordan Cove LNG Terminal and the Pacific Connector gas pipeline. Over 4,000 people have signed our petition opposing this project. A large portion of our petitions are on file in the FERC e-Library.1 We ask the DOE to note the filed petitions linked below as a reference, along with these additional submitted petitions we have included in with this filing as supporting justification that our intervention in this proceeding should be granted.
In addition, Citizens Against LNG would like to go on record as being in full support of the Sierra club and the Landowners United motion to intervene, protest and comments that are also being filed in this proceeding.
Please send any correspondence to:
Jody McCaffree Curt Clay Executive Director President Citizens Against LNG Citizens Against LNG PO Box 1113 PO Box 1113 North Bend, OR 97459 North Bend, OR 97459 [email protected] [email protected]
Sincerely,
Jody McCaffree
1 Petition Filing 1) http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20070326-0003 Petition Filing 2) http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20070906-0013 Petition Filing 3) http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20091112-5040 - Exhibit P
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Citizens Against LNG Inc PO Box 1113 North Bend, OR 97459
August 6, 2012
By Email and by Electronic Filing on the Federal eRulemaking Portal under FE Docket No. 12–32–LNG: [email protected] http://www.regulations.gov
Ms. Larine A. Moore Docket Room Manager FE-34 U.S. Department of Energy PO Box 44375 Washington, D.C. 20026-4375
Re: Application of Jordan Cove Energy Project, L.P. for Long-Term Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations, FE Docket No. 12-32-LNG
Dear Ms. Moore:
Please accept for filing the following protest of Citizens Against LNG Inc regarding the application of Jordan Cove for Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations. For the following reasons, we believe the Department of Energy should reject Jordan Cove’s application because it would be detrimental to the public interest.
1. Jordan Cove’s proposed export facility would hurt consumers in the United States by increasing the prices for domestic natural gas
It is not in dispute that Jordan Cove’s proposed LNG export facility would increase the price for domestic natural gas in the United States. The only question is how much domestic natural gas prices in the United States would increase and how badly this would impact consumers. According to the latest assessment of the U.S. Department of Energy, allowing LNG export facilities, including Jordan Cove’s proposed LNG export facility, would raise domestic natural gas prices substantially, by as much as 54% under certain scenarios:
“Increased exports of natural gas lead to increased wellhead prices in all cases and scenarios. The basic pattern is evident in considering how prices would change under the Reference case (Figure 3):
• The pattern of price increases reflects both the ultimate level of exports and the rate at which increased exports are phased in. In the low/slow scenario (which phases in 6 Bcf/d
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of exports over six years), wellhead price impacts peak at about 14% ($0.70/Mcf) in 2022. However, the wellhead price differential falls below 10 percent by about 2026.
• In contrast, rapid increases in export levels lead to large initial price increases that would moderate somewhat in a few years. In the high/rapid scenario (which phases in 12 Bcf/d of exports over four years), wellhead prices are about 36 percent higher ($1.58/Mcf) in 2018 than in the no-additional-exports scenario. But the differential falls below 20 percent by about 2026. …..
• Slower increases in export levels lead to more gradual price increases but eventually produce higher average prices, especially during the decade between 2025 and 2035. The differential between wellhead prices in the high/slow scenario and the no-additional- exports scenario peaks in 2026 at about 28 percent ($1.53/Mcf), and prices remain higher than in the high/rapid scenario. ….
“In particular, with more pessimistic assumptions about the Nation’s natural gas resource base (the Low Shale EUR case), wellhead prices in all export scenarios initially increase more in percentage terms over the baseline case (no additional exports) than occurs under Reference case conditions. For example, in the Low Shale EUR case the rapid introduction of 12 Bcf/d of exports results in a 54 percent ($3.23/Mcf) increase in the wellhead price in 2018; whereas under Reference case conditions with the same export scenario the price increases in 2018 by only 36 percent ($1.58/Mcf). But the percentage price increase falls in later years under the Low Shale EUR case, even below the price response under Reference case conditions. Under Low Shale EUR conditions, the addition of exports ultimately results in wellhead prices exceeding the $9 per Mcf threshold, with this occurring as early as 2018 in the high/rapid scenario.”1 (Emphasis added).
In a recent Congressional Report prepared by the staff of Representative Edward J. Markey, the Department of Energy’s findings were summarized as follows:
“The United States faces a critical decision about whether to export natural gas following the rapid expansion of domestic production in recent years. The Department of Energy has already approved one export application and is currently considering eight others. If these applications are approved and the companies export at full capacity, the United States could soon be exporting more than 20 percent of current consumption. The Energy Information Administration has estimated that exporting even less natural gas than what is currently under consideration could raise domestic prices 24 to 54 percent, which would substantially increase energy bills for American consumers and could potentially have catastrophic impacts on U.S. manufacturing.”2
1 U.S. Department of Energy (January 2012) “Effect of Increased Natural Gas Exports on Domestic Energy Markets.” http://www.fossil.energy.gov/programs/gasregulation/authorizations/2011_applications/exhibits_11-128- LNG/15._EIA_Effects_of_increased_NG_exports_.pdf 2 Representative Edward J. Markey (March 2012) "Drill Here, Sell There, Pay More: The Painful Price of Exporting Natural Gas." http://democrats.naturalresources.house.gov/sites/democrats.naturalresources.house.gov/files/2012- 03-01__RPT_NGReport.pdf 2
Therefore, proposed LNG export facilities, including Jordan Cove’s proposed facility which could ‘substantially increase energy bills for American consumers and could potentially have catastrophic impacts on U.S. manufacturing’ are simply not in the public interest.
2. Jordan Cove’s proposed LNG export facility would likely cause a net loss in U.S. employment by causing job losses in manufacturing
Jordan Cove argues that its proposed LNG export facility would be in the public interest by creating jobs in Coos County. According to Jordan Cove’s application:
“The jobs impact of construction of the Jordan Cove Project will be consequential. On average, the Project will employ 1,768 workers a year, and it will create 1,530 indirect and 1,838 induced jobs a year. ….
“The employment impacts of the Jordan Cove Project in the typical operating year will include 99 direct jobs at the Jordan Cove terminal and the PCGP pipeline, 51 indirect jobs paid by Jordan Cove (Sheriff’s deputies, firefighters, tugboat crews and emergency planners), 404 other indirect jobs and 182 induced jobs for a total of 736 total jobs in Coos County.”3
What Jordan Cove did not consider is how these possible jobs gained in Coos County would be more than offset by jobs lost in U.S. manufacturing generally. According to the Industrial Energy Consumers of America:
“In regards to using natural gas for export as LNG, IECA supports free trade. At the same time, affordable, abundant natural gas is critical to U.S. manufacturing growth, which in turn is critical to the U.S. economy. The manufacturing sector uses one-third of all of the natural gas and one-third of all electricity (of which one-third is produced from natural gas) which fuels the employment of 12 million high-paid workers. As with any resource that is critical to America's economic growth, any decision to approve the export of natural gas should include a rigorous analysis of the potential impact on the domestic economy and job creation, and place a high priority on the manufacturing sector. ….
“Affordable and abundant natural gas is vital to the recent renaissance in the nation’s manufacturing sector. This renaissance has already contributed to up to a half million new American jobs. In fact, for every manufacturing job created, three to five additional jobs across the broader economy are also created. Natural gas is used as a fuel for the entire manufacturing sector, to make nitrogen fertilizer, and it is also used as a raw material for the production of chemicals that are converted into an immense array of products that are used every day. Manufacturing natural gas consumption creates far more jobs per unit of gas consumed than any other application. The chemical industry
3 Application of Jordan Cove Energy Project, L.P. for Long-Term Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations, FE Docket No. 12-32-LNG, at pages 21-22. 3
alone has estimated that over $35 billion dollars of U.S. investments will be made by abundant, affordable supplies of natural gas.”4
The Industrial Energy Consumers of America has concluded:
“Jobs created by natural gas export facilities are small, relative to the opportunities to increase manufacturing jobs. Higher resulting natural gas prices will negatively impact U.S. manufacturing employment and ultimately additional jobs across the broader economy as well.”5
Therefore, Jordan Cove’s proposed LNG export facility, which could cause job losses in U.S. manufacturing that outweigh job gains locally, is not in the public interest.
3. Coos Bay would suffer the aftermath of unemployment that follows temporary employment in large-scale construction works
Unemployment impacts after the construction phase of the Jordan Cove / Pacific Connector project will not be in the public interest. The high unemployment in rural areas such as Coos Bay would be devastating to the local economy and clearly would not be in the public interest.
In 2003/2004 Coos County built a natural gas pipeline from Coos Bay to the Williams Northwest Grants Pass lateral pipeline that that runs along the I-5 hwy. The Coos County pipeline was a $51M gamble sold to the public with the promise of 2,900 jobs for the county. Despite all the promises made by industry speculators, those jobs never materialized and that pipeline currently is only operating at 5 to 7 percent of its capacity.
Jordan Cove estimates that 1,110 different jobs would need to be filled to build their project but the average job would only last 14 months. (FEIS 4.8-11)6 After that there would be massive unemployment in the area and more people would be out of work than what we have now. The few jobs the facility would estimate to have as permanent jobs in no way justifies the public need for the facility. The Pacific Connector gas pipeline is estimated to end up with only 5 permanent employees after the construction phase of the pipeline is over. 7
The Portland State University Population Research Center estimated that in July 2007, the population of Coos County was 63,050 people; which represented about a 4 percent increase since 2000. The two closest cities to the proposed Jordan Cove LNG terminal are North Bend, with a population estimated at 9,830 people, and Coos Bay, with a population of about 16,210 in
4 July 16, 2012 letter from the Industrial Energy Consumers of America to the Brookings Institute. Re: Hamilton Project: “A Strategy for U.S. Natural Gas Exports” by Michael Levi. http://www.ieca-us.com/wp- content/uploads/07.16.12_IECA-Response-to-Brookings.pdf 5 Ibid. 6 FERC Final Environmental Impact Statement (FEIS) for Jordan Cove LNG Import Facility; http://www.ferc.gov/industries/gas/enviro/eis/2009/05-01-09-eis.asp Page 4.8-11 7 FERC Jordan Cove Import Terminal Final EIS -http://www.ferc.gov/industries/gas/enviro/eis/2009/05-01-09- eis.asp Page 4.8-22
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July 2007 (Proehl 2008). (FEIS 4.8-11) The 56 to 99 jobs promised by Jordan Cove would not make a significant impact to what is truly needed in the area and when you count the jobs that will be lost due to the facilities impacts, the project most likely will end up being a job loser.
There is already high unemployment in the area which has been a continual example of plundering by industry speculators who come to town with big promises of jobs and prosperity and leave us with boondoggles and rotting infrastructure and eyesores. It has been so bad here that several books have been written about our area, the most recent being Wim de Vriend's book, "The Job Messiahs", which came out just this last December and is now in its second edition. Other books include, "Plundertown, USA: Coos Bay Enters the Global Economy” and David Cay Johnston’s New York best selling book, "Free Lunch: How the Wealthiest Americans Enrich Themselves at Government Expense (and Stick You With the Bill)," where Johnston devoted two full chapters to Coos County.
4. Jordan Cove’s economic analysis rests on the mistaken assumption that U.S. water supplies will be adequate to sustain increased production of natural gas by hydraulic fracturing
Jordan Cove argues that domestic natural gas prices in the United States would not increase that much because the burgeoning use of hydraulic fracturing will continue to create a vast oversupply of domestic natural gas. However, hydraulic fracturing consumes large quantities of water and the continued burgeoning use of hydraulic fracturing rests on assumptions that water supplies will, in the future, be adequate to sustain the continued increased use of this technology.
However, this assumption is likely to be wrong. According to the Pacific Institute:
“There is some evidence that the water requirements for hydraulic fracturing are already creating conflicts with other uses and could constrain future natural gas production in some areas. For example, in Texas, a major drought in 2011 prompted water agencies in the region to impose mandatory reductions in water use. Water agencies, some of which sold water to natural gas companies, indicated they might have to reconsider these sales if the drought persisted. Natural gas companies also tried to purchase water from local farmers, offering $9,500 to nearly $17,000 per million gallons of water (Carroll 2011). Likewise, at an auction of unallocated water in Colorado during the spring 2012, natural gas companies successfully bid for water that had previously been largely claimed by farmers, raising concerns among some about the impacts on agriculture in the region and on ecosystems dependent on return flows (Finley 2012).
“Concerns over water availability are not limited to drier climates. Pennsylvania is generally considered a relatively water-rich state. However, in August 2011, 13 previously approved water withdrawal permits in Pennsylvania’s Susquehanna River Basin were temporarily suspended due to low stream levels; 11 of these permits were for natural gas projects (Susquehanna River Basin Commission 2011). While parts of the state were abnormally dry, the basin was not experiencing a drought at the time, suggesting that natural gas operations are already creating conflict with other uses under normal conditions. In many basins, the application of fracking is still in its infancy and
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continued development could dramatically increase future water requirements and further intensify conflicts with other uses.”8
The United States is experiencing one of the worst droughts in 60 years, and this is affecting energy production in the United States. According to a recent editorial in the New York Times:
“We’re now in the midst of the nation’s most widespread drought in 60 years, stretching across 29 states and threatening farmers, their crops and livestock. But there is another risk as water becomes more scarce. Power plants may be forced to shut down, and oil and gas production may be threatened.
“Our energy system depends on water. About half of the nation’s water withdrawals every day are just for cooling power plants. In addition, the oil and gas industries use tens of millions of gallons a day, injecting water into aging oil fields to improve production, and to free natural gas in shale formations through hydraulic fracturing.”9
If Jordan Cove’s application is approved and an LNG export facility is built in Coos Bay, then this facility would be contractually bound to continue LNG exports to Asia regardless of whether future drought conditions would constrain the use of hydraulic fracturing to produce natural gas domestically. This would drive up U.S. natural gas prices and would hurt consumers and businesses in the United States by indirectly causing water shortages and exacerbating water scarcity. This would not be in the public interest.
5. If Jordan Cove is mistaken about Asian demand for imported LNG, then the proposed export facility would be mothballed, but after causing substantial impacts during its construction
Jordan Cove cites to Asian demand for imported LNG as the rationale for building its proposed export facility. In its application, Jordan Cove stated:
“The Jordan Cove facility is the only LNG export terminal proposed for the U.S. West Coast. It is thus uniquely positioned among United States terminals, not only to source its natural gas from Canadian and U.S. Rockies supply basins and to serve Asian demand without the longer routes and Panama Canal transits necessary from the Gulf Coast, but also to provide specific advantages (in addition to the economic benefits already detailed) for gas markets in the United States, in the country’s two non-contiguous states of Alaska and Hawaii and in Oregon along the route of the new PCGP pipeline.
“Given North America’s enormous shale gas resources and the Asian demand for its production, there is little doubt that Pacific Northwest LNG export facilities will be built.”10
8 Pacific Institute (June 2012) "Hydraulic Fracturing and Water Resources: Separating the Frack from the Fiction." http://pacinst.org/reports/fracking/full_report.pdf 9 Webber, E. (July 23rd, 2012) “Will Drought Cause the Next Blackout?” The New York Times. 10 Application of Jordan Cove Energy Project, L.P. for Long-Term Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations, FE Docket No. 12-32-LNG, at page 27. 6
Jordan Cove has already demonstrated its inability to predict demand for natural gas imports and exports. Jordan Cove based the proposed Jordan Cove LNG import terminal in Coos Bay on predictions that an import facility would be needed to meet growing U.S. demand for natural gas imports from overseas. These predictions turned out to be wrong.
Jordan Cove’s assumption about sustained Asian demand for LNG imports is likely to be wrong as well; the same factors that created an oversupply of domestic natural gas would likely also create an oversupply of natural gas in Asia, curtailing demand for LNG imports from the U.S. and rendering a West Coast-based LNG export facility economically unviable. According to a recent report of the International Energy Agency:
“The size of unconventional gas resources in China is at an early stage of assessment, but it is undoubtedly large. At end-2011, China’s remaining recoverable resources of unconventional gas totalled almost 50 tcm, comprised of 36 tcm of shale gas, 9 tcm of coalbed methane and 3 tcm of tight gas.5 This is around thirteen times China’s remaining recoverable conventional gas resources. China’s shale gas resources lie in several large basins spread across the country, with plays in the Sichuan and Tarim Basins believed to have the greatest potential.
“The Chinese government has outlined ambitious plans for boosting unconventional gas exploration and production. These call for coalbed methane production of more than 30 bcm and for shale gas production of 6.5 bcm in 2015; the targets for shale gas output in 2020 are between 60 and 100 bcm. They are accompanied by the goal to add 1 tcm of coalbed methane and 600 bcm of shale gas to proven reserves of unconventional gas by 2015. In support of this effort, China plans to complete a nationwide assessment of shale gas resources and build nineteen exploration and development bases in the Sichuan Basin in the next four years. Efforts are also supported by the international partnerships that Chinese companies have formed in North America to develop shale gas acreage, which will provide valuable development experience. ….
“China’s huge unconventional gas potential and strong policy commitment suggest that these resources will provide an increasingly important share of gas in the longer term, though the pace of development through to 2020 – the key period of learning – remains uncertain. Because of China’s highly centralised regulatory and policy-making framework and the high priority placed on industrial and economic development, unconventional gas projects may face fewer hurdles stemming from environmental concerns than those in Europe or the United States.”11
Eastern Europe and Eurasia are also poised to vastly increase production of natural gas from unconventional gas resources. Unlike Jordan Cove, production of natural gas from these locations can supply Asia with natural gas by pipeline.12
11 International Energy Agency (2012) “Golden Rules for a Golden Age of Gas: World Energy Outlook Special Report on Unconventional Gas,” at pages 115-120. .http://www.worldenergyoutlook.org/media/weowebsite/2012/goldenrules/WEO2012_GoldenRulesReport.pdf 12 Ibid., at page 87. 7
The State of Oregon has found that Jordan Cove’s proposed LNG import facility would have had adverse impacts on private landowners and the environment because of this facility’s construction.13 If Jordan Cove is mistaken (again) about future demand for LNG exports and imports, then the proposed facility would cause adverse impacts on private landowners and the environment by building a facility that would not be economically viable to operate. This would not be in the public interest. (See Exhibits A-G)
6. Liquefaction of natural gas for export/import is energy intensive and greatly diminishes the benefits of using natural gas
The liquefaction of natural gas requires a great amount of energy to compress methane into a liquid. This inherently wastes a substantial portion of the natural gas, which is burned in order to provide power to run compressors at liquefaction facilities. According to Jordan Cove’s own study:
“Approximately 6.2 percent of the gas delivered to the JCEP terminal would be either consumed as fuel to operate the liquefaction process or be removed from the feed gas stream (trace sulfur compounds, carbon dioxide, nitrogen and water) prior to or during the liquefaction step. Any hydrocarbons recovered that have a higher molecular weight than methane will fuel the power plant.”14 (Emphasis added).
Transoceanic transport and regasification of LNG are also energy intensive processes. According to a life-cycle assessment prepared by researchers with the Tepper School of Business, and Department of Engineering and Public Policy Carnegie Mellon University comparing coal and LNG:
“The rated power of the LNG tankers ranges between 20 and 30 MW, and they operate under this capacity around 75% of the time during a trip (24, 25). The energy required to power this engine is 11.6MMBtu/MWh(26). As previously mentioned, some of this energy is provided by BOG and the rest is provided by fuel oil. A loaded tanker with a rated power of 20MW, and 0.12% daily boil-off rate would consume 3.88 million cubic feet of gas per day and 4.4 tons of fuel oil per day. The same tanker would consume 115 tons of fuel oil per day on they way back to the exporting country operating under ballast conditions. A loaded tanker with a rated power of 30 MW, and a 0.25% daily boil-off rate would get all its energy from the BOG, with some excess gas being combusted to reduce risks of explosion (22). Under ballast conditions, the same tanker would consume 172 tons of fuel oil per day.
“For LNG imported in 2003 the average travel distance to the Everett, MA LNG terminal was 2700 nautical miles (13, 27). In the future LNG could travel as far as far as 11,700 nautical miles (the distance between Australia and the Lake Charles, LA LNG terminal (27)). This range of distances is representative of distances from LNG countries to U.S.
13 State of Oregon's Motion to Reopen the Record and Request to Set Aside Order. December 2, 2011. 14 ECONorthwest Construction Impact Study, at page 4. 8
terminals that could be located on either the East or West coasts. To estimate the number of days LNG would travel (at a tanker speed of 20 knots (22)), these distances were used. This trip length can then be multiplied by the fuel consumption of the tanker to estimate total trip fuel consumption and emissions, and these can then be divided by the average tanker capacity to obtain a range of emission factors for LNG tanker transport between 2 and 17 lb CO2 equiv/MMBtu.
“Regasification emissions were reported by Tamura et al. to be 0.85 lb CO2 equiv/MMBtu (21). Ruether et al. report an emission factor of 3.75 lb of CO2 equiv/MMBtu for this stage of the LNG life-cycle by assuming that 3% of the gas is used to run the regasification equipment (28). The emission reported by Tamura et al. differs because they assumed only 0.15% of the gas is used to run the regasification terminal, while electricity, which maybe generated with cleaner energy sources, provides the additional energy requirements. These values were used as lower and upper bounds of the range of emissions from regasification of LNG.”15
These researchers with Carnegie Mellon University concluded.
“In addition to LNG, SNG has been proposed as an alternative source to add to the natural gas mix. The decision to follow the path of increased LNG imports or SNG production should be examined in light of more than just economic considerations. In this paper, we analyzed the effects of the additional air emissions from the LNG/SNG life- cycle on the overall emissions from electricity generation in the United States. We found that with current electricity generation technologies, natural gas life-cycle GHG emissions are generally lower than coal life-cycle emissions, even when increased LNG imports are included. However LNG imports decrease the difference between GHG emissions from coal and natural gas.”16
The magnitude of the environmental benefits of natural gas fade away when natural gas is liquefied for export and importation. In general, natural gas supplies should be consumed on the continent they are produced, without liquefaction. For this additional reason, the proposed Jordan Cove export facility is contrary to the public interest.
7. Because Jordan Cove is owned and controlled by foreign investors, any profits from the project would only benefit non-U.S. investors.
The N-FTA Federal Register notice for Jordan Cove states the following:
“…Both Jordan Cove and its general partner are owned by the two limited partners in Jordan Cove. The first, Fort Chicago LNG II U.S.L.P., a Delaware limited partnership owns seventy-five percent. It is wholly owned and controlled, through a number of
15 Jaramillo, P., et al (Sep 2007) “Comparative Life-Cycle Air Emissions of Coal, Domestic Natural Gas, LNG, and SNG for Electricity Generation Environ Sci Technol. 41(17):6290-6. http://www.fossil.energy.gov/programs/gasregulation/authorizations/2011_applications/exhibits_11-128- LNG/32._Jaramillo_ComparativeLCACoalNG.pdf 16 Ibid., at page 6294. 9
intermediate wholly owned and controlled companies, by Veresen, Inc., a Canadian corporation based in Calgary, Alberta, which, prior to its organization as a corporation, was Fort Chicago Energy Partners L.P., a Canadian limited partnership (although the name of the parent changed, the name of the subsidiary owning Jordan Cove did not)…’” (Emphasis added)
Fort Chicago Energy Partners L.P. is a Canadian limited partnership in which “only Canadians” are allowed to invest.
“Fort Chicago is organized in accordance with the terms and conditions of a limited partnership agreement which provides that no Class A Units may be held by or transferred to, among other things, a person who is a "non- resident" of Canada, a person in which an interest would be a "tax shelter investment" or a partnership which is not a "Canadian partnership" for purposes of the Income Tax Act (Canada).”17
Profits projected to be made by Jordan Cove would then be funneled out of the country to only foreign investors. This would not be in the public interest. 18
8. Obtaining natural gas from Hydro-Fracking techniques is not in the public interest
Jordan Cove Energy Project is currently proposing to export hydro-fracked gas from shale beds in Canada or the United States in the form of Liquefied Natural Gas (LNG). The LNG would be exported from their proposed LNG terminal to be located on the North Spit of Coos Bay in Coos County. Just because the industry has learned how to extract fossil fuel natural gas from shale bed formations does not mean this is a reliable, sustainable or environmentally friendly process. There are loads of factors that affect how much natural gas will actually be produced, and for how long.
The wave of fracking that is currently gong on across the country may soon find limitations due to the detrimental impacts of the fracking process itself. New research was recently published in the Proceedings of the National Academy of Sciences that concluded fluids from the Marcellus Shale are likely seeping into Pennsylvania’s drinking water.19 This means hydro- fracking contaminants will find their way into Pennsylvania’s water supply also. This issue has create a storm of controversy and after months of research and discussion, Nationwide Insurance issued a memo stating they had determined that the exposures presented by hydraulic fracturing were too great to ignore and they would not be covering fracking damage.20 Issues such as these
17 CNW Group, “Canadian Newswire Fort Chicago announces monthly cash distribution for September 2009” September 21, 2009 http://www.newswire.ca/en/releases/archive/September2009/21/c7157.html 18 Bloomberg - “Exports of LNG May Raise U.S. Prices as Much as 54%, Agency Says” - By Katarzyna Klimasinska – Jan 19, 2012 http://www.bloomberg.com/news/2012-01-19/lng-exports-may-spur- higher-u-s-natural-gas-prices-report-says.html 19 ProPublica – “New Study: Fluids From Marcellus Shale Likely Seeping Into PA Drinking Water” by Abrahm Lustgarten; July 9, 2012; http://www.propublica.org/article/new-study-fluids-from-marcellus-shale-likely-seeping-into-pa-drinking-water 20 The Huffington Post – “Nationwide Insurance: Fracking Damage Won’t Be Covered” AP | By MARY ESCH; 07/12/2012; http://www.huffingtonpost.com/2012/07/13/nationwide-insurance-fracking_n_1669775.html?utm_hp_ref=green 10
could spell a reduction or even a halting of fracking in some areas and as quickly as the shale bed fracking natural gas market has emerged; it could be gone, leaving fast amounts of land taken by the gas industry, possibly by eminent domain, and fossil fuel infrastructure to lay fallow.
9. Jordan Cove’s proposed LNG export facility will negatively impact existing local and sustainable jobs and industries in the Coos Bay area
9.1 Tourism and Recreation
According to a 2011 study by Dean Runyan Associates for the Oregon Tourism Commission, during the period of 2007 to 2011, direct spending from tourism travel brought in more than a billion dollars into Coos County, Oregon alone.21 Tourism travel dollars spent in the area have steadily increased every year going from 94.5 million in 1991 to 220.1 million in 2011. There are 3,090 employment jobs in Coos County related to this industry, a direct result of not developing our beaches, dunes and coastline.
Adjacent to the proposed Jordan Cove LNG export facility is a designated Dunes National Recreation Area that is used year round. In addition to this there is the Sunset Bay State Park and Campground which is also used year round along with multiple trails and beach areas in the area, some directly adjacent to the proposed Jordan Cove project. Other examples in the area include the Shore Acres State Park which has a Christmas light show every year that goes from Thanksgiving until New Years. The Park had an estimated 57,768 visitors for the 2011 light show. People came from 25 countries (other than the U.S.) and 42 states.22 Winter months can see just as many recreational and tourist activates as summer months in our Coos Bay area.
The Final Environmental Impact Statement (FEIS) for Jordan Cove’s Import Facility stated the following with regard to this issue: (Emphasis and photos are added)
FEIS Page 4.7-5: “…The top five recreational activities along southern Oregon beaches include walking (43 percent), relaxing in a stationary location (24 percent), walking dogs (10 percent), driving OHVs (8 percent), and beachcombing (3 percent) (OPRD 2002).”
FEIS Page 4.7-6: “…Sunset Bay State Park includes a beach, picnic tables, hiking trails, 27 full recreational vehicle (RV) hookups, 66 tent spaces, and eight yurts. A public golf course is next to the park. An OPRD study indicated that Sunset Bay State Park receives 800,000 visitors a year (Hillmann 2006)”
FEIS Page 4.7-6: “…The Oregon Islands National Wildlife Refuge is administered by the FWS, and covers 1,850 rocks, reefs, islands, and two headlands, spanning a total of 320 miles along the Oregon coast. The Oregon Islands National Wildlife Refuge provides sanctuary for seabirds and marine mammals….”
21 Oregon Travel Impacts 1991-2011p –May 2011; Dean Runyan Associates; Prepared for the Oregon Tourism Commission, Salem, Oregon; Page 83 - http://www.deanrunyan.com/impactsOR.html 22 Shore Acres State Park Holliday Light Show Stats: http://www.shoreacres.net/images/pdf/stats-hol-lts-2011- wp.pdf 11
Birds swim just off of tidal sand areas at low tide and several species leave footprints in the wet tidal sands where the LNG slip dock is proposed to be built.
According to the World Newspaper; Monday, November 02, 2009:
“Coos Bay got a bit of a tourism boost over the last several days, as 200 or so birders came to the bay to see a rare brown booby that is hanging out near Charleston. People came to scope out the tropical bird from places including Eugene, Portland, Bend, McMinnville, Coos Bay and Washington. The rare tropical bird showed up last week and
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is the fourth verified sighting of this species of bird in Oregon. The last local sighting was in October 2008, when a dead female washed ashore at Lighthouse Beach.”23
The Weyerhaeuser site where the Jordan Cove LNG Export facility is proposing to build is arguably one of the best birding destinations in Coos County and attracts a multitude of breeding, migrant and vagrant species year-round.24 There are species like Wilsons Phalarope and Ring necked Duck. This is a crucial stop-over location for shorebirds during migration where they can rest and refuel, building fat reserves to last them on the next leg of their migration flight.
Oregon has lost much of its shorebird habitat through urban development and filling in wetlands and this site is one of the last significant “refueling stations” left on the Oregon Coast. Shorebirds by the thousands feed in late summer and fall here…
FEIS Page 4.7-7: Figure 4.7-2 list 34 Recreational Areas that are within the LNG Zones of Concern along the waterway for the proposed LNG Marine Traffic.
FEIS Page 4.7-16: “…The Siuslaw National Forest administers the Oregon Dunes National Recreation Area (NRA). It extends 40 miles along the Oregon Coast between Florence and Coos Bay. The Oregon Dunes NRA contains the largest expanse of coastal sand dunes in North America, as well as a coastal forest and over 30 lakes and ponds. Recreational opportunities at the NRA include OHV use, hiking, camping, horseback riding, angling, canoeing, sailing, water-skiing, and swimming. Thousands of OHV owners take advantage of the three main off- highway riding areas within the Oregon Dunes NRA. The day use and overnight camping facilities are used by over 400,000 visitors a year…”
For an Oregon Department of Fish and Wildlife listing of county expenditure estimates for Fishing, Hunting, Wildlife Viewing, and Shellfishing in Coos County and Oregon, see footnote below25
Coos County Local Recreation Expenditures, 2008 % of % of All Category Value State Travel** Total* Hunting $904,977 2.90% N/A Fishing $2,551,433 3.30% N/A Wildlife Viewing $1,637,158 4.90% N/A Shellfishing $1,080,963 20.60% N/A Total $6,174,531 4.20% N/A
23 “Flocking to see a rare bird”; The World Newspaper; Monday, November 02, 2009 http://theworldlink.com/news/local/flocking-to-see-a-rare-bird/article_4c58af85-d571-52c5-b820- 3301baf6f9d3.html 24 “Site Guide: Weyerhaeuser Settling Pond Site on the North Spit of Coos Bay”, Tim Rodenkirk: Oregon Birds 32(2): Pg 68 - 72, Summer 2006 25 “Fishing, Hunting, Wildlife Viewing, and Shellfishing in Oregon - 2008 State and County Expenditure Estimates”; Prepared for the Oregon Department of Fish and Wildlife - Travel Oregon; DeanRunyan Associates; May 2009 http://www.dfw.state.or.us/agency/docs/Report_5_6_09--Final%20%282%29.pdf 13
Coos County Travel-Generated Expenditures, 2008 % of % of All Category Value State Travel** Total* Hunting $2,534,940 2.40% 1.40% Fishing $12,253,254 4.60% 6.70% Wildlife Viewing $14,110,950 3.10% 7.70% Shellfishing $4,552,379 14.70% 2.50% Total $33,451,523 3.90% 18.30%
The Jordan Cove Project will clearly negatively impact this industry and all the permanent and sustainable jobs it supports as well as many others. Incredulously, the ECONorthwest study did not take into account the economic impacts of Jordan Cove’s proposed LNG export facility on local tourism and recreation.
9.2 Commercial and Recreational Fishing
The ECONorthwest study did not include negative impacts to our commercial and recreational fishing fleet. This could include negative impacts from transiting LNG tankers, the negative impacts from additional Bay dredging, or negative impacts to salmon bearing streams crossed by the pipeline. This is despite the fact Coos Bay is the third most important harbor in the state of Oregon in terms of total personal income generated from commercial fishing (exceeded only by Astoria and Newport). Commercial landing data compiled by ODFW indicate that a total of $20.1 million worth of fish and shellfish were landed at Charleston in 2006.26
Landowners and non-profit groups who have done restoration projects to help restore fish runs in Southern Oregon will have their projects and efforts destroyed by the pipeline construction. This would not be in the public interest. (See Exhibits A, B)
FEIS Page 4.7-4: “…According to a 2005 study by the Oregon State Marine Board (OSMB) recreational boaters in Coos Bay took a total of 30,996 boat trips the previous year. Nearly 90 percent of the boat usedays involved fishing (including angling, crabbing, and clamming), 9 percent was for pleasure cruising, and the remainder was for sailing and water skiing. Forty percent of the boating activities in Coos Bay originated from the Charleston Marina, and 20 percent at the Empire ramp…”
FEIS Page 4.7-4: “…Recreational clamming and crabbing occurs year-round and brings tourism based revenue to the region. Crabbing occurs in the main channel areas from the Southern Oregon Regional Airport to the mouth of the bay around slack tides. Clamming occurs year-round in the mud flats of Coos Bay, but is subject to closure as necessary by the ODA Food Safety Division for reasons of public health (Oregon Department of Agriculture Food Safety Division 2008)….”
26 FERC Final EIS for Jordan Cove LNG Import Facility; http://www.ferc.gov/industries/gas/enviro/eis/2009/05- 01-09-eis.asp - Page 4.8-8 14
Photo to Left: People clamming at low tide in the Lower Coos Bay along Cape Arago Hwy.
Photo to Right: Evidence of Clams in the tidal areas where the LNG slip dock is proposed to be built.
The ECONorthwest study did not account for the total time it would take homeland security to clear the bay before an LNG tanker would transit through the bay, nor did the study account for an accurate number of potential ship transits through the bay. When Freeport LNG import terminal began operating in April of 2008, Petty Officer Second Class Richard Ahlers said it would probably take up to three hours for the boat and its security perimeter to pass through in the first arrivals. Each time a LNG ship crawls into the harbor there, water-borne authorities like the Coast Guard plan on shutting down all boat traffic in a 1,000-meter radius of the transiting LNG vessel. Surfside Beach Mayor Jim Bedward said the village boat ramp, once it opened, would be closed as the ships pass. The City Hall in Freeport would get a 92-hour warning of the oncoming ships but would keep knowledge of the high-security vessels’ arrival to themselves — for obvious reasons. 27/28
Likewise the Jordan Cove LNG facility consultants have shown that ship transits would have security zones that are very similar to Freeport except that in some cases security zones for Jordan Cove would encompass the entire width of the Coos Bay and would take from 90 minutes to two hours. This would be an extreme hardship on the Commercial fishing fleet that also need high slack tides in order to transit the Coos Bay.
In Coos County the Pacific Connector is slated to directly negatively impact native Olympia oysters in Haynes Inlet and also Clausen Oyster Company’s highly productive silver point Pacific oyster beds. Coos Bay is the largest commercial producer of shellfish in the state of Oregon. Pacific oysters are commercially raised in the mudflats of South Slough and Haynes Inlet and the upper bay east of McCullough Bridge. Clamming also occurs at Haynes Inlet. (FEIS page 4.7-17) In recent testimony provided by the Clausen Oyster Company, Lilli Clausen stated the following:
27 “Coast Guard preparing for port shutdowns”, The Facts, by Hunter Sauls, April 14, 2008 http://thefacts.com/story.lasso?ewcd=f482d0ca682cb716 28 Platts LNG Daily April 11, 2008 [subscription required] reports that the Sabine Pass LNG terminal expects to receive its commissioning cargo aboard the LNG carrier Celestine River today. In preparation for the arrival of the ship, the U.S. Coast Guard will impose a security zone at the Sabine Pass in Louisiana for approximately three hours between noon and 7 p.m…
15
“When the engineer and some other people representing LNG were in our office a few weeks ago my husband, Max, and I tried to explain that the proposed line was too destructive to our oyster business…” (See Exhibit E)
9.3 Timber Production
The Jordan Cove proposal will force a significant change and a significant cost increase in accepted tree farm and forest practices on agricultural and forest lands. Including but not limited to: ● Permanent loss of timber in pipeline right of way. ● Increased loss in timber production due to increased wind in the pipeline right of way. Coos County Commissioner, Fred Messerle, who is also a local private timber operator stated recently in public testimony, “Cutting and maintaining an extended “hard edge” in an existing and/or new stand of timber will dramatically increase the wind loss over the 40 year rotation and thus increase cost and decrease yield.” ● Increase risk of foot traffic and spread of disease and root rot. Pacific Connector’s plan will significantly change the accepted practices involved in raising a 40-year crop and/or in a worst case, eliminates the value of the land all together for timber production. ● Increased risk of noxious weed growth which negatively impacts timber production. ● An open vector (right of way) with dry grass and brush creates a path for fire to “run on.” This means an increase in fire hazard exposure and risk in currently high timber production areas. ● Project significantly changes and or increases the costs of accepted practices overall. According to Commissioner Messerle, “Timber harvesting (logging) has always had a very “thin margin” of profit. Logging is not a “get rich quick” proposition. Any change to accepted logging practices will increase costs, decrease margins and significantly change the cost of accepted forest practices.” (See Exhibit F)
Yankee Creek Forestry also issued similar statements with regard to the negative impacts this proposed LNG project and pipeline will have on timber production. (See Exhibit G)
Construction of the Pacific Connector pipeline would affect about 3,035 acres of forest and woodland, 623 acres of agricultural lands, 488 acres of grasslands-shrubland, and 131 acres of non- riparian vegetation. (FEIS page 5-9). Approximately 151 miles, or 66 percent, of the proposed pipeline route would cross private property, which could be taken by eminent domain. The remaining 79 miles (34 percent) of pipeline route would cross public lands administered by the BLM (18 percent), USFS (12 percent), BOR (0.14 percent), (FEIS page 4.8-25)
It is difficult enough for a small family owned operation to monitor and oversee its base operation. The Jordan Cove / Pacific Connector project will change family owned and operated practices and increase costs to timber production. Some businesses are likely to go out of business due to this increased cost.
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In addition, Jordan Cove did not analyze timber jobs that will be impacted and lost from the flooding of the market with 144 miles of forestlands that will be clear-cut for pipeline construction. This will force timber prices to an all time low which will negatively impact the industry even more than it already has been. It could take years to recover.
9.4 Loss of other Proposed Port Developments
The negative impacts of the Jordan Cove Energy / Pacific Connector pipeline project to bay area businesses, including future potential businesses, industries and land owners was not considered in Jordan Cove’s economic reports.
For example, on January 20, 2011 the Oregon International Port of Coos Bay presented the following diagram at their Port Commission meeting concerning a proposed Wind Project the Port is currently working on potentially developing.29
Unfortunately the proposed Jordan Cove Energy LNG Project Thermal Radiation Zones and Vapor Dispersion Zones would negatively impact the above proposed development as shown in the following diagrams below taken from the Final EIS of the Jordan Cove Import facility.30
29 January 20, 2011, Oregon International Port of Coos Bay Wind Development presentation: http://www.portofcoosbay.com/minutes/wind.pdf 30 FERC Final EIS for Jordan Cove / Pacific Connector - Diagrams of Jordan Cove's Thermal Radiation Zones and Vapor Dispersion Zones - Pages 4.12-19 and 4.12-21 : http://www.ferc.gov/industries/gas/enviro/eis/2009/05-01-09-eis.asp
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On October 8, 2010, FERC sent a letter to Jordan Cove requesting that Jordan Cove revise their Flammable Vapor-Gas Exclusion Zone requirements and modeling to be in compliance with PHMSA Recent Guidance contained in Title 49 CFR Part 193.2059.31 It is highly likely that the Jordan Cove facility’s hazard exclusion zones will end up being much larger than they currently are when they are calculated properly to be in compliance with PHMSA. This could have devastating impacts to other users of the harbor, adjacent landowners and industrial development including the Port’s proposed Oregon Gateway cargo terminal, which would not be allowed to operate in these hazard zones. Jordan Cove has not to date filed with FERC their revised Flammable Vapor Gas Exclusion Zone requirements and modeling. Clearly Jordan Cove is aware of this problem and by now the Port should be.
In December 2011, a revised Land Option Agreement with the Jordan Cove Energy Project took back a large portion of Henderson Marsh to the west of the Jordan Cove facility to satisfy these thermal radiation and flammable vapor gas exclusion zone requirements. These thermal radiation and flammable vapor gas exclusion zones must be controlled by the Jordan Cove Energy Project at all times and must remain within the property boundaries of the facility. This will put any planned development to the west of the proposed Jordan Cove facility, including the above proposed wind turbine development, at risk.
The Oregon International Port of Coos Bay says its proposed Marine Terminal Slip is being designed for the Jordan Cove LNG docking facility and other potential marine uses on the west side berth. But the Marine Slip will not likely be usable for purposes other than those associated with and/or controlled by the Jordan Cove Energy Project. At a recent site tour held on March 27, 2012, that was sponsored by the Jordan Cove Energy Project, Bob Braddock from Jordan Cove stated that the current proposed Marine Terminal Slip was only designed to handle one vessel. Presumably this is due to Jordan Cove's thermal radiation and vapor dispersion exclusion
31 October 8, 2010 letter requesting Jordan Cove Energy Project, L.P. provide the informing described in Enclosure 3 to assist the FERC in their review re the PHMSA Interpretations on the Part 193 Exclusion Zone Regulations under CP07-444. http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20101008-3036 18
zones referenced above and also the Coast Guard safety and security hazard zones proposed for the LNG facility and berth that will preclude the use of the berth for other purposes.
The safety and security hazard zones the Coast Guard has proposed to impose will encompass the LNG vessel both while the vessel is moored and even when the LNG vessel is not moored. When the LNG vessel is at the docking facility there will be a 150 yard security zone around the vessel to include the entire terminal slip and when there is no LNG vessel moored, the security zone shall cover the entire terminal slip and extend 25-yards in the waterway. (CG-WSA page 2)32 In addition, the Coast Guard has also set a moving safety/security zone for the LNG tanker ship that extends 500-yards around the vessel but ends at the shoreline. No vessel may enter the safety /security zone without first obtaining permission from the Coast Guard Captain of the Port who resides in the Portland, OR office.32
As a result of the above safety zones, the Port’s proposed Marine slip can realistically serve only LNG terminal purposes.
In addition, the ECONorthwest study assumes there will be only 80 - 90 shipments per year and not the more realistic number of between 186 - 232 LNG vessel harbor disruptions that would include LNG vessels both coming and leaving the lower Coos Bay during high slack tides. (See Exhibit J)
Detailed issues concerning Pollution, Noise, Visual Impacts, Security, LNG Hazards, Natural Hazards and Emergency Response were filed with the Federal Energy Regulatory Commission for the Jordan Cove LNG Import / Pacific Connector Docket numbers CP07-444-000 and CP07- 441-000. Most of these issues were never fully addressed and would apply whether you were importing or exporting LNG.33
FERC’s Order34 that was recently pulled had 128 Conditions of Approval, many highly unlikely that Jordan Cove would ever be able to meet. The impacts of these issues and the true negative effects of the Jordan Cove LNG proposal on jobs in tourism, recreation, real estate, fishing, clamming, crabbing, oyster harvesting, timber, etc, were not addressed or considered fully in any economic study.
10. The proposed project will not provide tax revenue to local government
The Jordan Cove LNG facility will not increase the tax base of Coos County. The facility will sit in an Enterprise Zone and will be exempt from paying taxes for 3 or more years. The facility
32 Coast Guard - LOR / WSR / WSA for Port of Coos Bay / Jordan Cove Energy Project: http://homeport.uscg.mil/mycg/portal/ep/contentView.do?contentTypeId=2&contentId=63626&programId=12590& pageTypeId=16440&BV 33 January 15, 2010, letter to FERC with detailed information on LNG Hazard information and studies; http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20100115-5057 34 December 17, 2009, FERC Order on the Jordan Cove / Pacific Connector LNG Import Project - Dockets CP07- 441-000; CP07-444-000 et al: http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20091217-3076
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also will sit in an Urban Renewal District for the North Spit, which is administered by the Oregon International Port of Coos Bay. Money received is to go to Urban Renewal for the North Spit. The Oregon International Port of Coos Bay has already announced at Port meetings how they plan on spending this money. It will not go into the County general fund for roads, schools, sheriffs, and other necessary county expenditures.
11. Jordan Cove proposed LNG export facility would create substantial risks to public safety
Building an LNG import-export terminal on dredging spoils located on a sand spit (an unstable sand dune area) directly across the bay from an airport runway, in the flight path of the runway, in an extreme tsunami inundation zone, in an earthquake subduction zone, in an area known for high winds and ship disasters, less than a mile from a highly populated city not only violates multiple safety codes and regulations but is not in the public interest.
The Jordan Cove LNG facility is not following gas industry recommended guidelines for the safe siting of LNG Ports and jetties, putting thousands of people in the Coos Bay area at risk.
11.1 Tsunami and Earthquake Hazards
The Jordan Cove Energy Project has never complied with FERC’s request to show that that their facility which will be located on dredging spoils on a sand spit in a natural hazard zone has met engineering designs in order to withstand a Cascadia subduction 9.0 earthquake event and/or a tsunami.35 Since it is not a matter of “if” but a matter of “when” a Cascadia subduction event will occur off of our Pacific West Coast, placing a hazardous LNG facility in these natural hazard zones would not be in the public interest.36 (See Exhibit H)
It is estimated to take 90 minutes to 2 hours for an LNG tanker to transit from K Buoy to the marine slip dock. It is also estimated that it will take around 15-20 minutes from the time of a Cascadia subduction earthquake event until a tsunami would come ashore in the Coos Bay. A new study from Oregon State University says that the South Coast has a 40 percent chance of experiencing a major earthquake and resulting tsunami sometime in the next 50 years. The study further suggests that that tsunami could have a greater impact on the South Coast — around Coos
35 December 17, 2009, FERC Order - pages 79-84, Conditions 52-65,70,74: http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20091217-3076 36 The World, Coos Bay – “Not a matter of ‘if’ It’s a matter of when. What will the South Coast look like after a major disaster?” Stories by Jessica Musicar, Nia Towne, Andy Rossback and Nate Traylor. Illustrations by Jeff Trionfante, Benjamin Brayfield and Andy Rossback The World | Posted: Saturday, August 7, 2010 http://theworldlink.com/news/local/not-a-matter-of-if/article_d4b8e520-a1f3-11df-89f5-001cc4c03286.html ● “Oregon geology: 'The next ‘Big One’ is imminent'”: Story Published: Oct 16, 2009; Courtesy OSU News & Communications; http://www.kval.com/news/tech/64534977.html: "…The release of pressure between two overlapping tectonic plates along the subduction zone regularly generates massive 9.0 magnitude earthquakes – including five over the last 1,400 years," Corcoran said. "The last 'Big One' was 309 years ago. We are in a geologic time when we can expect another ‘Big One,’… … "Prudence dictates that we overcome our human tendencies to ignore this inevitability," he added…”. ● Visit www.oregontsunami.org for more information on current tsunami maps and hazards in the vicinity of the Jordan Cove Energy LNG project. 20
Bay — than other areas of the west coast.37 According to the study’s authors, the clock is ticking fast. There is no consideration for this LNG ship transit hazard in the FERC FEIS or the Coast Guard Letter of Recommendation (LOR) or Water Suitability Assessment (WSA) or Jordan Cove’s 3/31/09 Emergency Response Memorandum of Understanding (MOU). There is no Emergency Response plan that encompasses this and/or other safety issues in regard to transiting LNG tanker ships, floating objects, adrift vessels, barges, etc. Effects of tectonic subsidence (prolonged changes in tidal elevation inherent in the earthquake source scenarios used for tsunami generation) were also not considered in the FERC FEIS.
11.2 LNG Safety and Security Hazard Guidelines and Impacts
Industry SIGTTO Guidelines,38 Sandia National Laboratory Guidelines,39 GAO Report Guidelines40 and the most recent U.S. Department of Energy report to Congress, "Liquefied Natural Gas Safety Research"41 are not being considered or followed. The FERC Final EIS did not address the project’s notable departures from industry standards or comments to them on those departures.38 It is not in the public interest to proceed with this proposed project until these issues are fully addressed.
If the Jordan Cove LNG project should proceed, LNG tanker ships will be transiting our Coos Bay harbor carrying around 39 million gallons of LNG. If only about 3 million gallons of LNG was to spill onto the water from an LNG tanker ship, flammable vapors from the spill could travel up to three miles42. If a pool fire was to develop, people up to a mile away would be at risk of 2nd degree burns in 30 seconds.39/40/41
37 Study: Coos Bay region in danger of megaquake” By KATU.com Staff, Published: Aug 1, 2012 http://www.kpic.com/news/local/Study-Coos-Bay-region-in-danger-of-megaquake-164645456.html ● Oregon State University - “13-Year Cascadia Study Complete – and Earthquake Risk Looms Large” 8-1-12 - http://oregonstate.edu/ua/ncs/archives/2012/jul/13-year-cascadia-study-complete-%E2%80%93-and-earthquake- risk-looms-large 38 “Site Selection & Design for LNG Ports & Jetties – Information Paper No. 14” - Published by Society of International Gas Tanker and Terminal Operators Ltd / 1997 http://www.dma.dk/themes/LNGinfrastructureproject/Documents/Risk%20analyses/sigtto- site%20selection%20and%20design%20lng%20ports%20jetties.pdf 39 SANDIA REPORT “Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water”; Mike Hightower, Louis Gritzo, Anay Luketa-Hanlin, John Covan, Sheldon Tieszen, Gerry Wellman, Mike Irwin, Mike Kaneshige, Brian Melof, Charles Morrow, Don Ragland; SAND2004-6258; Unlimited Release; Printed December 2004; http://www.fossil.energy.gov/programs/oilgas/storage/lng/sandia_lng_1204.pdf 40 United States Government Accountability Office, Report to Congressional Requesters, Maritime Security; “Public Safety Consequences of a Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need Clarification”, February 2007; GAO-07-316: http://www.gao.gov/new.items/d07316.pdf 41 U.S. Department of Energy report to Congress, "Liquefied Natural Gas Safety Research" ; May 2012 : http://www.fossil.energy.gov/programs/oilgas/storage/publications/DOE_LNG_Safety_Research_Report_To_Congr e.pdf [NOTE: Based on the data collected from the large-scale LNG pool fire tests conducted, thermal (fire) hazard distances to the public from a large LNG pool fire will decrease by at least 2 to 7 percent compared to results obtained from previous studies. In spite of this slight decrease, people up to a mile away are still at risk of receiving 2nd degree burns in 30 seconds should a LNG pool fire develop due to a medium to large scale LNG breach event. ] 42 “LNG and Public Safety Issues – Summarizing Current Knowledge about Potential Worst Case Consequences of LNG spills onto water”. Jerry Havens, Coast Guard Journal Proceedings, Fall 2005 21
11.3 Airport Issues and Hazards
The proposed Jordan Cove LNG facility and South Dune Power Plant and liquefaction facility are directly across the Bay in close proximity to the Southwest Oregon Regional Airport in North Bend. Airport airspace and hazard issues were not addressed properly in the FERC FEIS. LNG Tank Heights clearly violate Title 14 Code of Federal Regulations (CFR) Part 77, Objects Affecting Navigable Airspace. Many issues concerning this and other airport hazards were raised in comments to FERC (Docket # CP07-444-000 and CP07-441-000)43 The airport will clearly be impacted negatively in order for LNG vessels to safely transit our Coos Bay harbor. This would greatly affect many businesses in the area including the Bandon Dunes World Renowned Golf Course. Currently, there are no plans to prevent this impact and protect citizens in this area and that is not in the public interest. Issues involving LNG tanker passage and air space issues were also not addressed in the Coast Guard’s LOR, WSA or considered in Jordan Cove’s economic analysis.
11.4 Inadequate Emergency Response Resources
Emergency Response is inadequate with most Emergency Responders located in the Hazard Zones of Concern of the facility and LNG tanker transit. See Hazard Zone maps on FEIS pages 4.7-3,-7,-15.44 The Coast Guard WSA is not in line with the Gas Industry SIGTTO guidelines and recommendations nor the Sandia National Laboratories guidelines and recommendations. The Coast Guard did not account for many LNG potential hazards in the waterway, air and shoreline and they failed to consider or mention hazard issues listed in the Coos County Natural Hazards Mitigation Plan. They underestimated the number of annual vessel calls and included no plans for handling tsunamis and earthquakes in their reports.
“Once ignited, as is very likely when the spill is initiated by a chemical explosion, the floating LNG pool will burn vigorously…Like the attack on the World Trade Center in New York City, there exists no relevant industrial experience with fires of this scale from which to project measures for securing public safety.” – Statement by Professor James Fay, Massachusetts Institute of Technology
Sandia Laboratory's Dec 2004 Report; "Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water", states on page 83; "... The distance from the fire to an object at which the radiant flux is 5 kW/m2 is 1.9 km" (1.181 miles).
To clearly understand this one must understand that 5 kW/m2 is the heat flux level that can cause 2nd degree burns on exposed human skin in 30 seconds.
43 March 31, 2009 comment letter to FERC addressing Safety and Security issues / Airport Hazards / Tsunami and Earthquake hazards: http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20090331-5160 - & http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20090401-5170 44 FERC Final EIS for Jordan Cove / Pacific Connector http://www.ferc.gov/industries/gas/enviro/eis/2009/05-01- 09-eis.asp Pages 4.7-3,-7,-15
22
The FERC Jordan Cove Energy (Import) Project Final Environmental Impact Statement (FEIS) - Section 4-7, pages 4.7-3 and 4.7-15, has maps with diagrams of the structures that are within the LNG Ship Transit Route Hazard Zones of Concern.45 (See Exhibit I) According to the FERC Final Environmental Impact Statement for Jordan Cove (FEIS page 4.8-2), 16,922 people live in these hazard zones along the waterway and yet there is little concern given for their safety. Trees and burnable scrub brush cover our area. Secondary fires will be paramount should an LNG accident occur. The FERC FEIS ignored comments on these dangers. The Coos Bay area has one hospital; it does not have a “Burn Unit.” Neither the FEIS nor any public communication from Jordan Cove Energy Project, Inc. (“JCEP”) has suggested how the medical response to even a minor LNG hazardous event could be handled in light of our area’s obvious insufficiency of appropriate medical facilities and personnel.
Many of the guidelines for safety that are suggested in the gas industries “Society of International Gas Tanker & Terminal Operators” (SIGTTO)46 Information Paper No. 14 have been completely ignored in this terminal siting, including the following:
1) Approach Channels. Harbor channels should be of uniform cross-sectional depth and have a minimum width, equal to five time the beam of the largest ship
45 FERC Jordan Cove LNG Import FEIS pages 4.7-3 and 4.7-15: http://www.ferc.gov/industries/gas/enviro/eis/2009/05-01-09-eis.asp 46 Site Selection & Design for LNG Ports & Jetties – Information Paper No. 14 - Published by Society of International Gas Tanker and Terminal Operators Ltd / 1997 23
2) Turning Circles. Turning circles should have a minimum diameter of twice the overall length of the largest ship, where current effect is minimal. Where turning circles are located in areas of current, diameters should be increased by the anticipated drift. 3) Tug Power. Available tug power, expressed in terms of effective bollard pull, should be sufficient to overcome the maximum wind force generated on the largest ship using the terminal, under the maximum wind speed permitted for harbor maneuvers and with the LNG carrier’s engines out of action. 4) Site selection process should remove as many risk as possible by placing LNG terminals in sheltered locations remote from other port users. Suggest port designers construct jetties handling hazardous cargoes in remote areas where ships do not pose a (collision) risk and where any gas escaped cannot affect local populations. Site selection should limit the risk of ship strikings, limiting interactive effects from passing ships and reducing the risk of dynamic wave forces within mooring lines. 5) Building the LNG terminal on the outside of a river bend is considered unsuitable due to fact that a passing ship may strike the berthed carrier if the maneuver is not properly executed. 6) SIGTTO Examples given for reducing risk factors beyond normal operations of ship/shore interface include LNG terminal patrols of the perimeter of the offshore safety zones with guard boats and to declare the air- space over an LNG terminal as being a restricted zone where no aircraft is allowed to fly without written permission. 7) Restriction of the speed of large ships passing close to berthed LNG carriers.
Also ignored were some of the safety guideline preventative measures in the Sandi National Laboratories Report – “Guidance on Risk Analysis and Safety Implications of Large Liquefied Natural Gas (LNG) Spill Over Water” – Dec 04:47
1) Appropriate off-shore LNG ship interdiction and inspections for explosives, hazardous materials, and proper operation of safety systems; 2) Appropriate monitoring and control of LNG ships when entering U.S. waters and protection of harbor pilots and crews; 3) Enhanced safety zones around LNG vessels (safety halo) that can be enforced; 4) Appropriate control of airspace over LNG ships; and 5) Appropriate inspection and protection of terminal areas, tug operations prior to delivery and unloading operations.
47 Without an emergency response plan to review it is hard to know if some of these recommendations have been met. Page 4.8-9 of FEIS states, “The Coos County Airport District, which operates the airport, has stated that the airport would not have to stop operations while an LNG carrier was transiting in the waterway past the airport.” “…and the Coos Bay Pilots Association foresees no delays for airplanes using the airport resulting from LNG marine traffic in the waterway.” This clearly violates Sandia’s safety guideline preventative measure recommendations. 24
Conclusion
It may be in the financial interest of some Canadian energy company to export domestic natural gas across the United States and across Oregon landowner’s private property. But it is contrary to the public interest. Exporting Canadian and domestic natural gas from Jordan Cove will (1) put Coos Bay area residents at risk in the event of a Magnitude 9 earthquake and tsunami; (2) deprive many landowners of the full use of their private property; (3) negatively impact Oregon forests and waterways; (4) increase the costs for residential, commercial, and industrial natural gas users; and (5) negatively impact businesses and industries in Oregon and in other parts of the United States. The DOE should not grant such a permit for Jordan Cove to export LNG to non-free trade agreement nations when it is clearly not in “the public interest” both nationally and locally to do so.
Sincerely,
Jody McCaffree Executive Director, Citizens Against LNG Inc
25
Citizens Against LNG Index for Exhibits
Exhibit A - Coos Watershed Association, May 13, 2010, comment letter on Pacific Connector Gas Pipeline Coos County CUP #HBCU-10-01.
Exhibit B - Declaration of Russell R Lyon on Pacific Connector Gas Pipeline Case No. CV-10- 6279-HO
Exhibit C - Williams / Metcalf, May 13, 2012, comment letter on Pacific Connector Gas Pipeline Coos County CUP #HBCU-10-01.
Exhibit D – McCauley, May 11, 2012, comment letter on Pacific Connector Gas Pipeline Coos County CUP #HBCU-10-01.
Exhibit E - Clausen Oyster, May 13, 2010, comment letter on Pacific Connector Gas Pipeline Coos County CUP #HBCU-10-01.
Exhibit F - Messerle and Sons, June 10, 2010, comment letter on Pacific Connector Gas Pipeline Coos County CUP #HBCU-10-01.
Exhibit G - Yankee Creek Forestry/Jake Robinson, June 7, 2010, comment letter on Pacific Connector Gas Pipeline Coos County CUP #HBCU-10-01
Exhibit H - Current 2012 Tsunami Evacuation Map of Jordan Cove Project area
Exhibit I - Jordan Cove LNG Tanker Hazard Zones from FERC Final EIS page 4.7-3
Exhibit J - Calculation of the approximate number of LNG Ship Transits needed to liquefy .8 and 1 billion cubic feet of gas per day and transport using 148,000 cubic meter ships.
Exhibit A Coos Watershed .-\ssociation P.O. Box 5860 \~AY 1 3 LUlU Charleston, OR 97420 (541) 888-5922 E-mail: [email protected] ~SSociatio{\ Web: www.cooswatershed.org Coos Watershed Association May 13,2010 Board of Directors J.R Herbst, Presidellt Ms. Patty Evernden, Planning Director Confederated Tribes of the Coos, Lower Umpqua, and Coos County Planning Department Siuslaw Indians 250 N. Baxter Marry Giles, Vice-Presidellt Coquille, OR 97423 Wavecrest Discoyenes
DOli Yost, Treasl/rer RE: Written Comments on Pacific Connector Pipeline #HBCU-lO-Ol Citizen-at-Large
DellI/is TI/rowski, Seeretory Dear Ms. Evernden, Bureau of Land Managemen By a consensus vote without objection, the Board ofDirectors ofthe Coos jim YOI/llg, Past-Presidel/t OR Dept. of rorestry Watershed Association at its regular meeting on May 10,2010 authorized me to provide these written comments on the environmental effects ofthe Conditional Reese Bl!llder Northwest Steelheaders Use Permit HBCU-lO-Ol to construct the Pacific Connector Liquefied Natural Gas (LNG) pipeline. The Association takes no position as to the merits ofthis DOli Brelage Brelage Pacific Dairy project, but feels that certain aspects ofthe Hearings Board Conditional Use (HBCU) permit that affect watershed concerns need to be addressed. Based on Mike Grqybill South Slough National the Proposed Route WC-lA from the FERC DEIS, which is the alignment being Estuarine Research Reserye considered for the HBCU, we would like to provide information related to this Tom HoeslY route. Menasha-Campbell Group 1. The alignment ofProposed Pacific Connector Pipeline (Route Alternative Bob LL1port Coos County Forestry WC-lA) as identified in the Notice ofLand Use Hearing does not follow a path of least environmental disturbance in the area covered by the Coos Bay jim Lyol/s Ocean Terminals Estuary Management Plan (CBEMP) ofthe Coos County Zoning and Land Development (CCZLDO). Alternative routes are available that would Joall Mabaffy Agriculture significantly reduce construction impacts and long term right-of-way
POIIIMerz maintenance impacts to streams and wetlands. Specifically, the Amended FV.Joanne Blue Ridge Alternative Route includes a ridgeline alignment beginning at
Dave i\1.esserle approximately MP 8 on the Proposed Route WC-lA in Section 20 ~lesscrle & Sons (T.25S.;R.12W.) and joining with the Blue Ridge Route Variation in Section SI/salllla Nordbojf 33 (T.25S.;R.12W.). This route would avoid the impacts to lowland areas Cape Arago Audubon (particularly wetlands), while reducing the number ofstream crossings. This Society "Amended Blue Ridge Alternative Route" largely follows the ridgeline Jasoll FJchorr/sol/ between the Catching Slough and Daniels Creek watersheds, and is Weyerhaeuser Company consistent with the design strategies identified in the Jordan Cover/Pacific Greg Stolle Connector FERC DEIS to reduce environmental impacts. Stuntzner Engineering 2. This route crosses two significant streams (Kentuck Slough and Willanch Slough), both ofwhich have high value for coho salmon. The area downstream from the proposed crossing at Willanch Slough is presently Jon A. Souder, Ph.D. Executive Director being considered for a Wetland Mitigation Bank, while the area upstream has had significant and successful riparian restoration projects. Information on the biological resources in these areas is available in our Coos Bay Lowlands Watershed Assessment (www.cooswatershed.org). 3. The route down Lilienthal Creek (T.25S.;R.12W., Sections 20 and 30) will cross the entirety ofthe Brunschrnid Wetland Reserve Project (WRP) that has a perpetual easement held by the U.S.D.A. Farm Services Agency. This site has had significant restoration work during 2008 and was completed in the winter of2009. Juvenile coho salmon (a Federally-listed Threatened species) were found during fish surveys in this wetland. We expect chronic sedimentation problems to occur in this wetland and Lilienthal Creek ifthe pipeline parallels the stream down this valley.
4. Across East Bay Drive-and hydrologically connected to the Brunschrnid WRP-are high quality tidal fringe wetlands (low and high salt marsh) adjacent to the Cooston Channel that have also been identified as having potential for long-term protection and enhancement. These wetlands are in CBEMP zones 18RS, 18A-CA and 18B-CA. The area includes sites (U-12 and U-16(a)) identified as "high" priority for wetland mitigation as a Management Objective (§4.5.480), and this use would appear to be precluded by a 50' LNG pipeline right-of-way. Because juvenile coho salmon were found upstream in the Brunschrnid WRP, they will also use this site.
5. Once it crosses the Coos River the proposed pipeline route will traverse lowlands adjacent to Catching Slough and its tributaries (approximately MP 8.25 to MP 18). These areas provide some ofthe most significant current lowland habitat for coho and Chinook salmon rearing, potential wetland restoration opportunities, and needed riparian restoration to reduce summer stream water temperatures. Ofparticular impOliance are Stock Slough (MP 10.1), the crossing in lower Catching Slough (MP 11), and Boone Creek (MP 15.75). All these streams and sloughs are used by coho salmon, and the adjacent riparian areas provide resources for these fish and other aquatic life. Additional information on these resources is found in the recently completed Catching Slough Assessment and Action Plan in the Publications section of our website (www.cooswatershed.org).
The Coos Watershed Association is interested in working with Coos County and Williams Pipeline consistent with our mission to "support environmental integrity and economic stability within the Coos watershed." In addition to our watershed assessments and restoration action plans, we have a deep knowledge of local conditions and landowner concerns in the project area in the Coos Bay Frontal watershed, as well as experience in designing and implementing water quality and habitat restoration and road upgrade projects. We would be happy to discuss such possibilities with the project proponents as plans progress.
Please don't hesitate to contact me ifyou have questions or need additional information.
Cordially, rtl~&-
Jon A. Souder, Ph.D. Executive Director
Pursuant to the CCZLDO Section 5.7.300.4.B(4), I certify that Dr. Jon A. Souder is authorized to provide these comments on behalf ofthe Coos Watershed Association.
~~/2az.,I-~~--JL:"'~~~C:::-;::::;:::;;:::~ Date: __~--,-I-----,-I2L+-1_1-=-u __ JR ~ PreSIdent
Exhibit B Case 6:10-cv-06279-HO Document 6-4 Filed 09/13/10 Page 1 of 7 Page ID#: 148
Susan Jane M. Brown (OSB #054607) Western Environmental Law Center 4107 N.E. Couch Street Portland, Oregon 97232 Tel: 503-914-1323 Fax: 541-485-2475 [email protected]
Attorney for Applicants-in-Intervention/Defendants
UNITED STATES DISTRICT COURT DISTRICT OF OREGON EUGENE DIVISION
PACIFIC CONNECTOR GAS PIPELINE, LP, a Case No. CV-10-6279-HO Delaware limited partnership;
Plaintiff, DECLARATION OF RUSSELL R. LYON vs.
LOUISE SOLLIDAY, in her official capacity as Director of the Oregon Department of State Lands; and RICHARD WHITMAN, in his official capacity as Director of the Oregon Department of Land Conservation and Development;
Defendants, and
BOB BARKER, JOHN CLARKE, BILL GOW, RUSS LYON, and MARY MARGARET MUENCHRATH, individuals; and OREGON WOMEN’S LAND TRUST, a nonprofit corporation;
Applicants-in-Intervention/Defendants.
I, RUSSELL R. LYON, do hereby declare and state:
1. My name is Russell R. Lyon. I make this declaration based on my own belief and
knowledge.
PAGE 1 – DECLARATION OF RUSSELL R. LYON Case 6:10-cv-06279-HO Document 6-4 Filed 09/13/10 Page 2 of 7 Page ID#: 149
2. My property, which I own with my wife Sandra G. Lyon, is located at 3880 Days Creek
Road, Days Creek, Oregon, 97429.
3. The Pacific Connector pipeline would cross through our property.
4. We have a 306-acre ranch consisting of farm and forest land.
5. There are two large creeks on our ranch. Days Creek runs east to west near the southern
edge for almost the full length of our property before turning south, and Fate Creek runs north to
south near the western edge. Nestled between these two creeks at the southwest corner, our
house and barns are spread out on about five acres.
6. The proposed 36-inch diameter pipeline transporting unscented natural gas at 1400psi,
buried as little as 2 to 3 feet under the surface, will cross the southwest corner of our ranch
within less than 500 feet of our house.
7. I understand that the minimum safe blast zone around this type of high pressure gas line
is 900 feet.
8. The pipeline would first enter our property on the western side, cutting southeast through a pasture before crossing Fate Creek (at pipeline milepost 88.48) within 500 feet of our house. It would then exit our property through another pasture before crossing Days Creek south of our property, but still within 500 feet of our house, and as it turns to head southeast.
9. The proposed pipeline would rip open 75 foot wide swaths across any stream or river, and create a 100 foot wide scar everywhere along its route.
10. I would like to tell you about the Fate Creek Project.
11. Fate Creek is a small stream in Douglas County, Oregon. It is a poster child, so to speak, of what citizens can do to improve our water quality and salmon habitat. Back in 1990, my wife and I searched all over the West for a spot to settle down and raise our family in a healthy
PAGE 2 – DECLARATION OF RUSSELL R. LYON Case 6:10-cv-06279-HO Document 6-4 Filed 09/13/10 Page 3 of 7 Page ID#: 150
environment. When we moved to Days Creek, Oregon, it fulfilled all our dreams of a rural environment off the beaten track, away from many of man’s detrimental impacts on the
environment. Never in our wildest dreams did we imagine that a huge natural gas pipeline
would be proposed right through our property. (The first map from Pacific Connector
Corporation showed it going right through our very house!)
12. My wife and I purchased a historic cattle ranch which, through our hard labor, we turned
into an organic farm.
13. We have spent 18 years improving our environment, and in particular, Fate Creek. We
sought out and worked with the local Soil and Water Conservation District, our local Watershed
Council, Oregon Department of Fish and Wildlife, and the Bureau of Land Management (BLM)
to carry out numerous improvement projects to this small rural stream to restore its historic
salmon runs.
14. As a tributary to Days Creek, which in turn is a tributary to the South Umpqua River,
Fate Creek is part of one of the Pacific Northwest’s prime salmon recovery areas. Before we
started our restoration efforts, Fate Creek had no salmon spawning in it. The creek was not
fenced so that the cattle were degrading banks and fouling the waters.
15. Fate Creek now has nearly 2 miles of fence that keep the livestock out of the creek. Two
bridges have been installed to allow cattle to be moved across without going through the creek.
An off-stream stock-water system has been installed to provide livestock the water they need without entering the riparian zone.
16. There was a 14 foot dam for irrigation diversion, a second smaller 8 foot dam, and a culvert crossing Days Creek Road, that all prohibited fish passage. That culvert has now been replaced, and also one on the BLM lands upstream from us. The smaller dam has been totally
PAGE 3 – DECLARATION OF RUSSELL R. LYON Case 6:10-cv-06279-HO Document 6-4 Filed 09/13/10 Page 4 of 7 Page ID#: 151
removed, and the larger dam has been retrofitted with a huge gate valve which is left open during
the fall, winter, and spring providing unimpaired fish passage.
17. In addition, a large riparian restoration project was done where blackberries were
removed and replaced with native trees and shrubs to provide further shading in addition to the
existing large trees. This September 2010, log/boulder structures are being placed in both Fate
and Days Creeks to restore the natural instream habitat that would have historically existed.
18. Fate Creek and its restoration efforts will be a show place of riparian restoration
possibilities for public tours to show other ranchers and landowners how restoration efforts can
be beneficial to both land-managers and wildlife. Coho, a listed fish species, are now spawning
and rearing once again in Fate Creek after years of absence.
19. The proposed pipeline crossing right through this restoration project area would destroy
all of this effort.
20. In order to build the pipeline, a large swath of riparian trees will be removed and not be
allowed to be replanted.
21. The history of past pipeline projects shows that they have major problems with erosion
and continually contribute to water turbidity. This will reverse all of the positive things we’ve
been able to do on Fate Creek.
22. As landowners along the pipeline route, my wife and I have been very frustrated by the
pipeline representatives and how they deal with landowners, so we have not given Pacific
Connector access to our property.
23. Their environmental and social arrogance has been amazing.
24. The idea of using eminent domain, with minimal compensation for our loss of well-being
and decreased property values, is, of course, of large concern.
PAGE 4 – DECLARATION OF RUSSELL R. LYON Case 6:10-cv-06279-HO Document 6-4 Filed 09/13/10 Page 5 of 7 Page ID#: 152
25. But, also the very long-lasting environmental damage that will occur over the 280-mile
pipeline route and its 379 water body crossings – as well as on our land – are of equal or greater
concern.
26. I have watched and heard from the beginning the pipeline representatives give whatever
answer they thought would work to relieve landowner concerns.
27. For example, a meeting was held July 2009 at the proposed crossing site of Fate Creek
that involved Pacific Connector Pipeline Company’s lead project engineer, environmental
scientist, lead router, and two land agents; Oregon Department of Fish and Wildlife district
biologist; executive director and project planner from Partnership for the Umpqua Rivers; an
Oregon Department of Forestry engineer; and our family.
28. The Oregon Department of Fish and Wildlife had flagged the Fate Creek crossing in their
response to the DEIS because of the numerous restoration work and projects in the creek.
29. From our meeting, it was immediately clear to us that Pacific Connector representatives
didn’t have a clear concept of the impact the crossings would have. The disruption of the
ecosystem, the erosion of soils, added turbidity in the watershed, the loss of shade from the
removal of mature trees, and the introduction of invasive species from contaminated equipment
needed to be addressed. Their answer to nearly all the very real concerns was that, if there were
a problem, mitigation somewhere else would make up for the local destruction and damage.
30. This lack of understanding and caring about the impact of the pipeline on landowners was
offensive.
31. Why is all of this important? As stated above, salmon are now spawning again in Fate
Creek, and the water quality has greatly improved because of the work and money put into
PAGE 5 – DECLARATION OF RUSSELL R. LYON Case 6:10-cv-06279-HO Document 6-4 Filed 09/13/10 Page 6 of 7 Page ID#: 153
improving our streams by those of us who cared. The proposed natural gas pipeline would cross right through Fate Creek.
32. Fate Creek is not the only such stream in the Umpqua watershed where large salmon recovery projects have been carried out. The local watershed council, alone, has spent over ten
million dollars to improve fish habitat in the Umpqua watershed. The proposed pipeline will
cross dozens of streams as well as going under our major rivers. Precious riparian areas will be
mowed down and denuded causing loss of stream cover and spawning habitat.
33. My wife and I were told that there will be minimal disruption, but the past record of a
pipeline between Roseburg and Coos Bay has proven otherwise. Drilling can cause underground
blowouts and produce desecration of our waters for years to come.
34. We have worked for years now to protect and increase shade cover for our streams. The
pipeline would rip open 75 foot swaths across our streams and rivers, and create 100 foot scars
across our hillsides and mountains, which consist of greatly varied soil types and stabilities.
35. Oregonians appreciate our natural landscape and are proud of our forests and rivers. The
terminal and its pipeline would degrade our environment and put our lives at risk, all for no
benefit to Oregonians. Oregonians would receive a very small fraction of this gas, if any.
36. Besides this environmental damage, the social and economical disruption along the
pipeline could be extensive. Our own property and lives will definitely be impacted. The
pipeline will cross through our irrigated pastures, trees will be cut down, and our driveway and
fields will be used for staging areas.
37. Does anyone really believe that we would have any chance of selling our home, at
anywhere near its current value, while a 36 inch un-scented high pressure gas pipeline is buried
PAGE 6 – DECLARATION OF RUSSELL R. LYON A portion of this document at this location is being withheld for redaction of Personally Identifiable Information. A redacted version of this document will be posted when that process is complete. Exhibit C
A portion of this document at this location is being withheld for redaction of Personally Identifiable Information. A redacted version of this document will be posted when that process is complete.
Exhibit D A portion of this document at this location is being withheld for redaction of Personally Identifiable Information. A redacted version of this document will be posted when that process is complete. STATE OF OREGON COUNTY OF coos CERTIFICATE OF WATER RIGHT .. ; :
W;f)ig 3Jg to (terti!!', That GRAD>ON R. THOM, JR.
of Rou"te 3. Box 220, Cooe Bay , State of Oregon , has made proof to the satisfaction of the STATE ENGINEER of Oregon, of a right to the use of the waters of . ~ . ,I!, a spring i: a tributary oj unnamed s1:l-eam for the purpose of ; ~atIl1J.y domeS'tic use of one < i:, I : i under Permit No. J0562 of the State Engineer, and that said right to the use of said waters ! :i has been pe'"fected in accordance with the laws of Oregon; that the priority of the right hereby i I confirmed dates from June ,15. 1965 l! i I
that the amount of wllter.to which such right is. entitled and hereby confirmed, jor the purposes aforesaid, is limited to im amount actually beneficially usecl for said purposes, and shall not exceed 0.01 CUbic' :root; per second
or its equivalent in case of rotat~~~i measured at the point of diversion from the stream. ~wt;". The point of diversion is located in the NEt- Bec'tion 30. T. 26 B., R. 12 W. t W.M. Spring located. 230 ~:eet Sou'th end 1660 feet East t'rom NW Corner, Sec'tion 3O~
The amount of water used for irr:gation, together with the amount secured under any other right existing for tile same lands, shall be limited to __ - of one cubicJoot per second per acre,
and shall conform to such reasonable rotation system as may be ordered by the proper state officer. A description of the place of use under the right hereby confirmed, and to which such right is ... appurtenant, is as follows:
Lot 1 The right to the use of the water for the purposes aforesaid is restricted to the lands or place of use herein described. WITNESS the signature of the State Engineer, affixed this date. June 17 t 1969 .. CHRIS L. lJHEEI.m ····.. · Recorded in State Record of Water Right Certificates, Volume 28 ,page :;6042 Exhibit E I CLAUSEN OYSTERS 66234 North Bay Road North Bend, Oregon 97459 USA (541) 756-3600 Max & Lilli Clausen (541)267-3704 Fax (541) 756-3200 May 13,2010 Kimberly D Bose, Secretary Federal Energy Regulatory Commission We are very concerned about the route of the pipe line through Haynes Inlet and the bay on the West side of Highway lOll I realize that the diagonal path through Silverpoint I oyster bed was changed to run alongside the oyster bed. ', ' However, according to the documentary we were shown some time · ago, when a pipeline is constructed in the water, mud and sand are suspended in the water, especially on windy days, and would drift over our oyster beds which would kill our oysters. Another problem is the fact when the line is build, the ground over the pipe and the right-of -way is altered to the point where it acts like quicksand. Our oyster crew could not cross there. They usually leave the boat at the edge of the oyster bed and walk to the predetermined site to fill the nets at low tide. The nets are later retrieved at high tide with the oyster barge hoist. When the engineer and some other people representing LNG were in our office a few weeks ago my husband, Max, and I tried to explain that the proposed line was too destructive to our oyster business. Studying the maps it seems more logical and doable to swing away from our oyster plant from Haynes Inlet and continue straight West, North of Horsefall Beach Road, tunnel under Highway 101 through North Slough where nothing is planted due to poor water quality and ground conditions. There could even be a half mile saved in total distance to offset some of the additional cost. Considering that the line is starting on the California border; crossing many roads and streets, this should be a possible solution without destroying our business. We do not like the idea of having a pipe line a few hundred feet from our oyster plant, but at least it would not impact our daily commute to and from the oyster beds. Most of the ground in the Northern part of Haynes Inlet is owned by the Division of State Lands while most of the ground in the North Slough IS Coos County ground. . Please have your engineers take another look to alter the route to run North of Horsefall Beach Road, as sketched on the enclosed map. That change would eliminate any potential interference in our daily boating and harvesting activities, and hopefully also keep any harmful sediment away from our very productive oyster bed. In effect, you would not need our permission to survey this area, since your future installation would not take place on our land. Thaukyou! V(;/tl~~f? /,(j -: .. .. . ~ . - . :. , . \: ~ , ':'.;: ';'( .. a .:· .:.. · ·':.) .' , " , . \ ) ,f ,1. I \ . I 1 " . / \ \ / \ :::::~:~; ~'::M'': .i::;,\r;.~·;~::t:/·:~;~::~ :.:·.~i::::': .:::.:'::::..... , ...... •. .. ~·.w ... ,.t...... •••••• ,/ ..) I ~ , { :i:~1~w.1li~~~~~I~~~ff~:;,j:~i:i;, ...... ~·· .. ,rPi4········ .. :···:· .. · ".' ...... ; -.- t · ,- ... -- - _/ .:':', ' '." .....,.: ... ~ ,• .... , I ./ .. I I' I' n.d'uslri,al Waste I I ~ , Ponds : I J ~ I : I I "_~ - . . ~ . f : / / • # ( '\ Exhibit F Exhibit G Exhibit H Exhibit H Current 2012 Tsunami Evacuation Map of Jordan Cove Project area Orange – Distant Tsunami evacuation zone Yellow – Local Cascadia Earthquake and Tsunami evacuation zone Full Tsunami Evacuation Map for Coos Bay Area available at: http://www.oregongeology.org/pubs/tsubrochures/CoosBayEvac.pdf (4.03 MB) Proposed South Dunes Power Plant Project Facilty Proposed Jordan Cove Energy Project Facilty Exhibit I Jordan Cove LNG Tanker Hazard Zones (FEIS Page 4.7-3) No one is expected to survive in Zone 1 (yellow) - Structures will self ignite in this zone just from the heat. People in Zone 2 (green) will be at risk of receiving 2nd degree burns in 30 seconds on exposed skin. People in Zone 3 are still at risk of burns if they don’t seek shelter but exposure time is longer than in Zone 2. Map does not include the hazard zones for the South Dunes Power Plant. Exhibit J EXHIBIT J Calculating 148,000 cubic meter LNG ship at – 600 to 1 and 610 to 1 conversion from Natural Gas and how many shipments that would mean: 148,000 cubic meters LNG = 5,226,570.675 cubic feet LNG 5,226,570.675 X 600 = 3,135,942,405 cubic feet of natural gas 292,000,000,000 cubic feet of gas (yearly) :/: 3,135,942,405 cubic feet of gas per shipload = 93 shipments needed per year = 186 harbor disruptions at high slack tide. [Note: Jordan Cove non-FTA Application page one says JCEP will export 292 billion cubic feet (Bcf) per year (.8 Bcf/d ); Page 13 states .9 Bcf/d beginning in 2017; ECONorthwest Construction Impact Study page 3 states; “ The PCGP would have a nameplate capacity of 1.1 billion cubic feet of natural gas per day (Bcfd). At a 90 percent capacity factor, throughput would average 0.99 Bcfd.” Page 5 states; “A single natural gas compressor station at Malin will allow the PCGP to transport 1.1 Bcfd to JCEP terminus in Coos County.”] *************************************************************************** 148,000 cubic meters LNG = 5,226,570.675 cubic feet LNG 5,226,570.675 X 600 = 3,135,942,405 cubic feet of natural gas 365,000,000,000 cubic feet of gas (yearly) :/: 3,135,942,405 cubic feet of gas per shipload = 116 shipments needed per year = 232 harbor disruptions at high slack tide ***************************************************************************** 148,000 cubic meters LNG = 5,226,570.675 cubic feet of LNG 5,226,570.675 X 610 = 3,188,208,111.75 cubic feet of natural gas 365,000,000,000 cubic feet of gas (yearly) :/: 3,188,208,111.75 cubic feet of gas per shipload = 114 shipments needed per year = 228 harbor disruptions at high slack tide ***************************************************************************** 116 shipments: /: 12 (months) = Ten shipments per month (roughly) A shipment every 2 – 3 days. Some of the LNG is left in the ship to keep the containers cold and there is also LNG lost to boil off (about 15 % per shipment by some estimates) that has not been figured into these estimates. Who’s to say that the minute the DOE and FERC would approve this, Jordan Cove Energy Project would submit another application to increase their export capacity? Another good question would be what is the pollution impact of having all these smaller ships? Right now most of the newer ships being built are much larger than 148,000 cubic meters - www.coltoncompany.com Citizens Against LNG Petition Exhibit (Set 4 Beginning #501) A portion of this document at this location is being withheld for redaction of Personally Identifiable Information. A redacted version of this document will be posted when that process is complete. Exhibit 3 Jody McCaffree Individual / Executive Director Citizens Against LNG PO Box 1113 North Bend, OR 97459 September 12, 2012 By Email [email protected] [email protected] Ms. Larine A. Moore Docket Room Manager FE-34 U.S. Department of Energy PO Box 44375 Washington, D.C. 20026-4375 Re: Answer of Jordan Cove Energy Project, L.P. to Protests of Application for Long- Term Authorization to Export Liquefied Natural Gas to Non-Free Trade Agreement Nations, FE Docket No. 12-32-LNG Dear Ms. Moore: Please accept for filing the following response of Citizens Against LNG to the recent “Answer” filed by the Jordan Cove Energy Project (JCEP) dated August 29, 2012. We received this document by postal mail only a few days ago and even though the document has yet to appear in the U.S. Department of Energy Office of Fossil Energy e-library web portal for FE Docket No. 12–32–LNG, we feel a response is warranted in this case. The Jordan Cove “Answer” included yet another ECONorthwest report that was dated May 14, 2012, and titled, “The Impact of the Jordan Cove Energy Project on Coos County Housing and Schools.” As previously explained in our August 6, 2012, protest comments, the U.S. Department of Energy Office of Fossil Energy should take a closer look into the ECONorthwest reports being submitted by the Jordan Cove Energy Project. The following supporting evidence is being provided to you in addition to our previously submitted documentation to help give you a better understanding as to why a thorough independent economic analysis is in order by the U.S. Department of Energy. In October 2006 the South Coast Development Council (SCDC) in Coos Bay, Oregon, who fully supported the proposed Jordan Cove liquefied natural gas (LNG) import project, engaged the Portland-based ECONorthwest to forecast the net economic benefits of the proposed Jordan Cove LNG project. The report, “Forecast of the Net Economic Benefits of a Proposed LNG 1 Terminal in Coos County, Oregon,” 1 was used as a justification for the Jordan Cove LNG import facility and was relied on by the Federal Energy Regulatory Commission (FERC) in the preparation of the Environmental Impact Statement (EIS) that led to the FERC Order approving the project in 2009. The ECONorthwest report was flawed for several reasons in that it did not include negative economic impacts that would have occurred as a result of the proposed Jordan Cove LNG import facility, nor did the report confirm the specifics as to the high number of jobs they were predicting would result due to Jordan Cove’s operations. We now know the 2006 predictions and projections by ECONorthwest were incorrect. On Feb. 29, 2012, Jordan Cove notified FERC that due to current market conditions they no longer intended to implement their Dec. 17, 2009, FERC Order authorizing them to construct and operate a LNG import terminal. FERC vacated the Order for the Jordan Cove import project on April 16, 2012. Obviously the Jordan Cove Energy Project would not have produced the economic benefits and jobs that the 2006 ECONorthwest report had predicted would occur from the importation of LNG. The U.S. Department of Energy should consider taking a thorough investigative review of the ECONorthwest reports similar to what the United States Department of Agricultural (USDA) Rural Development did in 2008. In December of 2008, the USDA Rural Development questioned the reliability and accuracy of an ECONorthwest report that was being used to justify a $6 million dollar proposed expansion of the Salmon Harbor resort in Winchester Bay, Oregon. The USDA did their own investigation and found the ECONorthwest projections used to justify the proposed expansion were not feasible, nor were the ECONorthwest conclusions warranted. As a result of the investigation, the USDA pulled their funding for that proposed project. (See Exhibit A) Likewise, the U.S. Department of Energy Office of Fossil Energy should not rely solely on the economic projections being provided by the Jordan Cove Energy Project. Before our property rights, businesses, people and the environment are potentially put at risk there should be an in-depth, complete and accurate economic analysis that includes the impacts on the public both now and in the future from exporting LNG. As we stated earlier in our August 6, 2012, protest comments on page 7: “Jordan Cove has already demonstrated its inability to predict demand for natural gas imports and exports. Jordan Cove based the proposed Jordan Cove LNG import terminal in Coos Bay on predictions that an import facility would be needed to meet growing U.S. demand for natural gas imports from overseas. These predictions turned out to be wrong. “Jordan Cove’s assumption about sustained Asian demand for LNG imports is likely to be wrong as well; the same factors that created an oversupply of domestic natural gas would likely also create an oversupply of natural gas in Asia, curtailing demand for LNG imports from the U.S. and rendering a West Coast-based LNG export facility economically unviable….” An example of the kind of economic analysis that should be done by the U.S. Department of Energy can be found in the 2006 Passamaquoddy Whole Bay Study (Part 1) that was completed 1 “Forecast of the Net Economic Benefits of a Proposed LNG Terminal in Coos County, Oregon” An Economic Impact Analysis Prepared for the South Coast Development Council – October 16, 2006 ; ECONorthwest 2 by Yellow Wood Associates, Inc.2 Citizens of three nations, the United States, Canada and the Passamaquoddy Tribe, commissioned the Whole Bay Study to determine what the potential costs and benefits of one or more LNG terminals in Passamaquoddy Bay would mean from the perspective of Bay communities. The focus of the Part 1 Whole Bay Study was on direct employment impacts on local residents and businesses, economic impacts on the real estate market, and fiscal impacts related to community infrastructure, transportation, housing, public safety and property values. Unlike the ECONorthwest reports being presented to the U.S. Department of Energy Office of Fossil Energy by the Jordan Cove Energy Project, the Passamaquoddy Whole Bay Study looked at both economic benefit and loss. Part 1 of the Whole Bay Study concluded that there was no net gain that was realized overall by these LNG facilities and that the economic stimulus provided to a region by one or more LNG import terminals would be limited. The study also concluded the following: “…LNG is not a local resource. The beneficiaries of LNG development, including both investors and consumers, will be overwhelmingly from away. LNG is not a renewable resource. LNG is not an inexpensive form of energy. Even if LNG were made available through pipeline extensions and connections to local communities, it would not shield these communities from price hikes dictated by multinational corporations and the global economy. Nor would it increase the capacity of local communities to meet their own energy needs affordably today and in the future… “...Economic Diversification A diversified economic base in which the elements are compatible and synergistic is widely viewed as contributing to the health, resiliency, and vitality of rural communities. Diversity means that no single employer dominates the market, no single landowner dominates the tax rolls, and no single buyer determines the fate of the community. “ Several of the LNG terminals proposed for Passamaquoddy Bay communities are offering millions of dollars in “support” to host communities in an attempt to make their development proposals more palatable. Although millions of dollars sounds like (and is) a lot of money in the context of a small rural community, in the context of LNG, it is very little. Each proposed terminal on Passamaquoddy Bay has the capacity to handle more than $1 billion worth of natural gas each year at present prices. Local communities need to be aware of the trade-offs made in accepting such “support.” Once a single corporate entity comprises the majority of the tax base, communities rapidly lose the capacity and ability to make independent decisions regarding local services and investments...”3” 2 “Report on Potential Economic and Fiscal Impacts of LNG Terminals on the Whole Passamaquoddy Bay”. Prepared by Yellow Wood Associates, Inc – June 20th 2006 http://www.savepassamaquoddybay.org/documents/community_impact_studies/whole_bay_study/whole_bay_study /WholeBayStudy-Part_1.pdf “Study: Impacts of LNG costly, benefit limited”, Edward French; THE QUODDY TIDES Newspaper; Vol. 38, No. 14; June 23, 2006; http://quoddytides.com/lng6-23-06.html 3 “Report on Potential Economic and Fiscal Impacts of LNG Terminals on the Whole Passamaquoddy Bay”. Prepared by Yellow Wood Associates, Inc – June 20th 2006 – Page 121 3 The Yellow Wood Associates determined that a more thorough study would be required to determine the extent to which any economic gains that do result from LNG may be offset by damage to existing sections and that may create new obstacles of future economic diversification and sustainability. Citizens in rural poor areas such as Coos Bay, Oregon, do not have the resources that the multinational corporations and the gas and oil industry have to conduct such a thorough independent analysis. We citizens depend on agencies such and the United States Department of Agricultural (USDA) Rural Development and the U.S. Department of Energy to do such an analysis for us and to make sure their decisions are in the public interest. It would “not” be in the public interest of our fishing, timber, clamming, crabbing, oyster growing, farming, tourism, recreation and industries that use natural gas for the U.S. Department of Energy to make a decision on Jordan Cove exporting LNG to non-free trade agreement nations based solely on economic projections and reports provided by the Jordan Cove Energy Project. The decision as to whether Jordan Cove should be allowed to export LNG to nations that do not have a free trade agreements with the United States should be based on a rigorous independent economic and environmental impact analysis that includes “all” potential impacts (both negative and positive) of exporting natural gas from both natural gas produced domestically in the United States and natural gas produced in Canada. The analysis should encompass all proposed and potential LNG export proposals in North America. Sincerely, /s/ Jody McCaffree Jody McCaffree cc: DOE/FE [email protected] [email protected] DOE/GC [email protected] By postal mail to all persons listed in the Service list for FE Docket No. 12-32-LNG 4 EXHIBIT A The World – Coos Bay http://theworldlink.com/news/local/feds-say-no-to-resort-funding/article_9b6904dc-b754-5a19- a23c-409471752788.html Feds say no to resort funding Monday, December 28, 2009 By Alex Powers, Reedsport Staff Writer REEDSPORT — Federal officials have pulled funding for the Salmon Harbor Marina’s proposed Phase III expansion to its resort. In a letter dated Dec. 14 to the Port of Umpqua, Clem Singer, Roseburg area director for USDA Rural Development, told commissioners “there remains some serious doubt” if the expansion could pay for itself. The nearly $6 million expansion calls for 46 new campsites, a bathroom and an about $1.8 million, 9,576-square-foot community building in Winchester Bay. According to an economic impact study prepared in 2008 by Portland-based ECONorthwest, that center could draw guests to the park during winter, a time of year that historically sees low usage from RVs. The study said in its first year, the expanded RV resort is expected to make $426,855 and more each year after that. “It’s not feasible. That building is not going to pay for itself. It’s just not,” Singer said. Singer said USDA was not satisfied with ECO Northwest’s projections. “The conclusions that they drew weren’t warranted, in our opinion,” he said. He said USDA also examined the occupancy earlier this year at Lakeside’s Osprey Point RV Resort, Woahink Lake RV Resort and Sea Perch RV Resort in Yachats. “All three of those, we were told, have high wintertime occupancy,” Singer said. USDA found they have few guests during winter. Harbor Master Jeff Vander Kley said Salmon Harbor cannot become a special district and tax for revenue. It may look to Douglas County for assistance. “This effort to expand the RV resort was to reduce the need for the county … contributions to the operations,” Vander Kley said. “It’s a big conundrum.” County Commissioner Susan Morgan asked the marina earlier this month to re-evaluate ECONorthwest’s analysis. Marina project manager Linda Noel said the marina probably will plug updated cashflow information from the resort into the original report, while Vander Kley said the agency may consider downsizing or phasing the project. 5 CERTIFICATE OF SERVICE I hereby certify that in accordance with 10 C.F.R. § 509.107 (c), I have this 12th day of September 2012 caused a copy of the foregoing to be served by mail to the following individuals listed in the Service list for FE Docket 12-32 LNG: Elliott L. Trepper, President Jordan Cove Energy Project, L.P. 125 Central Avenue, Suite 380 Coos Bay OR 97420 Joan M. Darby, Attorney for Jordan Cove Energy Project Dickstein Shapiro LLP 1825 Eye Street NW Washington DC 20006-5403 Clarence Adams Landowners United 2039 Ireland Road Winston, OR 97496 David Schryver, Executive Vice President The American Public Gas Association 201 Massachusetts Avenue , Suite C-4 Washington DC 20002 William T. Miller, Attorney Miller, Balis & O'Neil, P.C. Twelfth Floor 1015 Fifteenth Street, N.W. Washington DC 20005 Lesley Adams,Program Director Rogue Riverkeeper P.O. Box 102 Ashland, OR 97520 Joseph Vaile, Program Director Klamath-Siskiyou Wildlands Center P.O. Box 102 Ashland, OR 97520 Nathan Matthews, Attorney Sierra Club Environmental Law Program 85 Second Street, 2nd Floor San Francisco, CA 94105 6 Kathleen Krust, Paralegal Sierra Club Environmental Law Program 85 Second Street, 2nd Floor San Francisco, CA 94105 Sincerely, /s/ Jody McCaffree Jody McCaffree 7 Exhibit 4 Exhibit 4 http://www.dailymail.co.uk/sciencetech/article-2208953/Shock-report-claims-100m- people-die-economic-growth-drop-3-2-2030-climate-change-ignored.html Ignore climate change and 100m people will die by 2030, shocking new report claims By DAILY MAIL REPORTER PUBLISHED: 26 September 2012 | More than 100 million people will die and global economic growth will be cut by 3.2 percent of gross domestic product (GDP) by 2030 if the world fails to tackle climate change, a report commissioned by 20 governments has claimed. As global average temperatures rise due to greenhouse gas emissions, the effects on the planet, such as melting ice caps, extreme weather, drought and rising sea levels, will threaten populations and livelihoods, said the report conducted by humanitarian organisation DARA. It calculated that five million deaths occur each year from air pollution, hunger and disease as a result of climate change and carbon-intensive economies, and that toll would likely rise to six million a year by 2030 if current patterns of fossil fuel use continue. More than 90 percent of those deaths will occur in developing countries, said the report that calculated the human and economic impact of climate change on 184 countries in 2010 and 2030. It was commissioned by the Climate Vulnerable Forum, a partnership of 20 developing countries threatened by climate change. 'A combined climate-carbon crisis is estimated to claim 100 million lives between now and the end of the next decade,' the report said. It said the effects of climate change had lowered global output by 1.6 percent of world GDP, or by about $1.2 trillion a year, and losses could double to 3.2 percent of global GDP by 2030 if global temperatures are allowed to rise, surpassing 10 percent before 2100. It estimated the cost of moving the world to a low-carbon economy at about 0.5 percent of GDP this decade. British economist Nicholas Stern told Reuters earlier this year investment equivalent to 2 percent of global GDP was needed to limit, prevent and adapt to climate change. His report on the economics of climate change in 2006 said an average global temperature rise of 2-3 degrees Celsius in the next 50 years could reduce global consumption per head by up to 20 percent. 1 Temperatures have already risen by about 0.8 degrees Celsius above pre-industrial times. Almost 200 nations agreed in 2010 to limit the global average temperature rise to below 2C (3.6 Fahrenheit) to avoid dangerous impacts from climate change. But climate scientists have warned that the chance of limiting the rise to below 2C is getting smaller as global greenhouse gas emissions rise due to burning fossil fuels. The world's poorest nations are the most vulnerable as they face increased risk of drought, water shortages, crop failure, poverty and disease. On average, they could see an 11 percent loss in GDP by 2030 due to climate change, DARA said. 'One degree Celsius rise in temperature is associated with 10 percent productivity loss in farming. 'For us, it means losing about 4 million metric tonnes of food grain, amounting to about $2.5 billion. 'That is about 2 percent of our GDP,' Bangladesh's Prime Minister Sheikh Hasina said in response to the report. 'Adding up the damages to property and other losses, we are faced with a total loss of about 3-4 percent of GDP.' Even the biggest and most rapidly developing economies will not escape unscathed. The United States and China could see a 2.1 percent reduction in their respective GDPs by 2030, while India could experience a more than 5 percent loss. The full report is available here: http://daraint.org/climate-vulnerability-monitor/climate-vulnerability-monitor-2012/report/ Executive Summary here: http://www.daraint.org/wp-content/uploads/2012/09/EXECUTIVE-AND-TECHNICAL- SUMMARY.pdf 2 Exhibit 5 REPORT: CLIMATE CRISIS ALREADY CAUSING UNPRECEDENTED DAMAGE TO WORLD ECONOMY; HUMAN IMPACT ON LARGE-SCALE New and comprehensive assessment of the costs of climate change • Inaction on climate change already causing over one trillion dollars in losses • Costs to escalate rapidly: global GDP stunted by over 3 percent by 2030 – crisis to increasingly hold back growth if urgent action is not taken Climate change and carbon economy linked to 5 million deaths each year • High-level political, scientific and economic leaders call for international action to halt surge in losses to human life and the world economy hitting all nations NEW YORK, Wednesday 26 September 2012 – DARA and Climate Vulnerable Forum report: Most comprehensive ever assessment of the current global impact of climate change released today. 20 governments commissioned the independent report, the first of its kind to show that tackling the global climate crisis would already reap significant economic benefits for world, major economies and poor nations alike. “Climate Vulnerability Monitor” study’s findings point to unprecedented harm to human society and current economic development that will increasingly hold back growth, on the basis of an important updating and revision of previous estimates of losses linked to climate change. KEY FINDINGS INCLUDE THE FOLLOWING ESTIMATES: • Climate change and a carbon-intensive economy considered a leading global cause of death today, responsible for 5 million deaths each year – 400,000 due to hunger and communicable diseases aggravated by climate change and 4.5 million carbon economy deaths due mainly to air pollution • Failure to act on climate change already costs the world economy 1.6% of global GDP amounting to 1.2 trillion dollars in forgone prosperity a year • Rapidly escalating temperatures and carbon-related pollution will double costs to 3.2% of world GDP by 2030 • Losses for lower-income countries are already extreme: 11% of GDP on average for Least Developed Countries already by 2030 • Major economies are heavily hit: in less than 20 years China will incur the greatest share of all losses at over 1.2 trillion dollars; the US economy will be held back by more 2% of GDP; India, over 5% of its GDP • Economic losses dwarf the modest costs tackling climate change: emission reductions at just 0.5% of GDP for the next decade; and support to the vulnerable: a minimum of 150 billion dollars per year for developing countries Climate Vulnerable Forum Chair, Bangladesh – one of the largest newly- emerging economies in Asia – represented by Prime Minister Sheikh Hasina officially launched the report at a major diplomatic event to coincide with the 67th session of United Nations General Assembly. Commenting on the report she said: “One degree Celsius rise in temperature is associated with 10% productivity loss in farming. For us, it means losing about four million metric tonnes of food grain, amounting to about US$ 2.5 billion. That is about 2% of our GDP. Adding up the damages to property and other losses, we are faced with a total loss of about 3-4% of GDP. Without these losses, we could have easily secured much higher growth.” “After seventeen years of international negotiations, we are still without any meaningful agreement or action to reduce global warming. As a climate vulnerable country, every day we see and feel the ramifications of that inaction as outlined in the Climate Vulnerable Monitor. But experts have struggled to tie all the pieces together to design a clear picture of climate vulnerability. This report examines impacts linked to climate change in some new ways and attempts to draw new conclusions. We did not have access to this information until now. Of course, experts may call into question this or that aspect of the Monitor’s findings, but we are certain subsequent research will continue to reaffirm the broad conclusions of the report. Its publication is a milestone for the climate negotiations. It is our hope it will help redirect efforts to effectively address the harms being done to today’s economy. We continue to work with all governments and other stakeholders to bring about a fair and just outcome to the negotiations.” The report is the second to be issued by an ongoing international research program on climate-related vulnerability mandated to the independent humanitarian and development research organization, DARA. Its expanded assessment of the costs of inaction on climate change presents a new and original assimilation of the latest scientific evidence, research and data in a survey of thirty-four indicators of climate-related concern. The study estimates human and economic impacts for 184 countries in 2010 and 2030 across a wide range of separate effects. Indicators of impact range from issues such as hunger and skin cancer, to permafrost thawing and sea-level rise, indoor and outdoor air pollution, and fisheries, biodiversity and forest deterioration. Constraints on labor productivity, imposed by rising heat, are the largest single impact due to climate change and a new component of the analysis. High-level and technical panels of over 50 leading scientists, economists, and policy experts, including former heads of government, reviewed the report whose development also involved field-based research in Africa and Asia. Report Panel member, DARA Trustee and Former President of Costa Rica José María Figueres said today: “1.3 billion people are still fighting their way out of the most extreme forms of poverty while major economies are today fighting their way out of crippling financial and economic crises. We simply cannot afford to part with more growth. The prospect of economic losses that rise with every decade could destabilize the world economy far before the worst impacts of climate change set in. Governments and international policy makers must act decisively to combat the spiraling costs to national and global GDP resulting from inaction on climate change. The Monitor shows how failure to do so has already caused unprecedented damage to the world economy and threatens human life across the globe. With the investment required to solve climate change already far below the estimated costs of inaction, no doubt remains as to the path worth taking.” The new Monitor report, entitled “A Guide to the Cold Calculus of A Hot Planet,” juxtaposes on the one hand the large-scale anticipated increases in fossil fuel consumption over the coming decades with the enormous human and developmental consequences of this. However, it also points out that decisions taken on cold monetary terms alone would actually favour strong action on climate change globally and regionally. The report outlines how the first edition of the Monitor is already used as a tool by development, humanitarian and aid agencies concerned with addressing the growing impact of climate change around the world, as well as investment and security analysts among others. Ends FOR ADDITIONAL COMMENT, INFORMATION OR TO REQUEST AN INTERVIEW WITH A DARA/FORUM SPOKESPERSON, PLEASE CONTACT: Daniel Rolle, MHP Communications [email protected] / +44 (0)203 128 8199 / +44 (0)7946 656 212 Tom Gillingham, MHP Communications [email protected] / +44 (0)20 3128 8151 / +44 (0) 7585 301 464 About the Monitor The Climate Vulnerability Monitor measures the global impact of climate change and the carbon economy at a national level. It calculates and compares the vulnerability for 184 countries in four areas of impact (environmental disasters, habitat change, health impact and industry stress) using 34 climate and carbon related indicators. The monitor uses five levels of vulnerability, from acute to low, to compare and contrast nations. The first Monitor was launched in 2010 to assess the effects of global climate change on nations up to 2030. It uses current peer-reviewed scientific research, in-country field research and critical input from two separate external advisory bodies. About DARA Founded in 2003, DARA is an international organization headquartered in Madrid, Spain, committed to improving the effectiveness of aid for vulnerable populations suffering from conflict, disasters and climate change. It is an impartial, non-partisan, non-profit entity independently governed by a foundation Board of Trustees and actively engaged in field research and evaluation work of aid programs and operations in developing countries across five continents. It also produces and issues specialized publications and data in particular on aid accountability and effectiveness issues, as well as emerging strategic concerns for the development, humanitarian and disaster reduction domains. DARA’s Climate Vulnerability Initiative is mandated to develop the Monitor as an independent and politically impartial report and convenes the external advisory bodies that provide third-party guidance and review inputs to this process. www.daraint.org About the Climate Vulnerable Forum Founded in 2009, the Climate Vulnerable Forum is a semi-formal government cooperation group of developing countries facing high degrees of insecurity due to climate change and active in seeking a resolution to the climate crisis. The Forum has called for ambitious outcomes in international climate change policy, such as setting the temperature increase goal at 1.5° Celsius (2.7° Fahrenheit) which was subsequently also adopted by other groups of countries and played an important boundary definition role in the UN climate negotiations at Copenhagen in 2009. The Forum has advocated for and insisted on accountability to decisions taken in international arena regarding climate change and sustainable development and its members have committed to pursue domestic low-carbon and even carbon neutral development pathways. The Forum currently has 20 members and meets periodically at head of government, ministerial and delegate levels. The Monitor is an analytical input and communication tool for Forum members, and the two country studies included in this report were undertaken in member countries, Ghana and Vietnam. Exhibit 6 ND CLIMATE VULNERABILITY MONITOR 2EDITION A GUIDE TO THE COLD CALCULUS OF A HOT PLANET Climate Vulnerable Forum 16 I EXECUTIVE SUMMARY EXECUTIVE SUMMARY This report provides a reassessment of the human THE MAIN FINDING OF THIS REPORT IS THAT and economic costs of the climate crisis. The CLIMATE CHANGE HAS ALREADY HELD BACK reassessment is based on a wealth of the latest GLOBAL DEVELOPMENT: IT IS ALREADY A research and scientific work on climate change and SIGNIFICANT COST TO THE WORLD ECONOMY, the carbon economy, research that is assimilated as WHILE INACTION ON CLIMATE CHANGE CAN BE a part of this report. CONSIDERED A LEADING GLOBAL CAUSE OF DEATH. CLIMATE – TOTAL COSTS CARBON – TOTAL COSTS W149% W57% 4% 4% 6% 18% 6% 12% 6% 32% 18% 21% 2030 2030 36% 2010 2010 54% 38% 41% 58% 46% Developed Developing Country High Emitters Developed Developing Country High Emitters Developing Country Low Emitters Other Industrialized Developing Country Low Emitters Other Industrialized CLIMATE – TOTAL DEATHS CARBON – TOTAL DEATHS W35% U1% 1% 14% 5% 4% 2% 15% 43% 4% 5% 2030 2010 2010 2030 83% 85% 48% 46% 45% Developing Country High Emitters Developing Country Low Emitters Developed Developing Country High Emitters Other Industrialized Developing Country Low Emitters Other Industrialized EXECUTIVE SUMMARY I 17 This report estimates that climate change causes the world’s oceans, the slow response of the carbon TECHNICAL SUMMARY 400,000 deaths on average each year today, mainly cycle to reduced CO2 emission and limitations due to hunger and communicable diseases that on how fast emissions can actually be reduced.1 The Monitor presents a new and affect above all children in developing countries. The world economy therefore faces an increase in original analysis, synthesizing Our present carbon-intensive energy system and pressures that are estimated to lead to more than a the latest research and scientific related activities cause an estimated 4.5 million doubling in the costs of climate change by 2030 to information on the global impact deaths each year linked to air pollution, hazardous an estimated 2.5% of global GDP. Carbon economy – including benefits and losses occupations and cancer. costs also increase over this same period so that – of climate change and the carbon economy in economic, environmental and health terms. OVERALL COSTS Climate change already causes Losses 2010, 400,000 deaths each year on Bln PPP Losses 2010, Net Losses, Net Losses, corrected USD % of GDP % of GDP 2010 % of GDP 2030 average. The present carbon- Climate 696 0.9% 0.8% 2.1% intensive economy moreover Carbon 542 0.7% 0.7% 1.2% is linked to 4.5 million deaths worldwide each year. Climate World 1,238 1.7% 1.6% 3.2% change to date and the present carbon economy are estimated Climate change caused economic losses estimated global GDP in 2030 is estimated to be well over to have already lowered close to 1% of global GDP for the year 2010, or 700 3% lower than it would have been in the absence of global output by 1.6% of world billion dollars (2010 PPP). The carbon-intensive climate change and harmful carbon-intensive energy GDP or by around 1.2 trillion economy cost the world another 0.7% of GDP in that practices. dollars (2010 PPP). Losses are year, independent of any climate change losses. Continuing today’s patterns of carbon-intensive expected to increase rapidly, Together, carbon economy- and climate change- energy use is estimated, together with climate reaching 6 million deaths and related losses amounted to over 1.2 trillion dollars change, to cause 6 million deaths per year by 2030, 3.2% of GDP in net average in 2010. close to 700,000 of which would be due to climate global losses by 2030. If The world is already committed to a substantial change. This implies that a combined climate-carbon emissions continue to increase increase in global temperatures – at least another crisis is estimated to claim 100 million lives between unabated in a business-as-usual 0.5° C (1° F) due to a combination of the inertia of now and the end of the next decade. A significant fashion (similar to the new IPCC RCP8.5 scenario), yearly average global losses to world NUMBER OF DEATHS output could exceed 10% of 2010 2030 global GDP before the end of Diarrheal Infections 85,000 150,000 the century, with damages accelerating throughout the Heat & Cold Illnesses 35,000 35,000 century. The costs of climate Hunger 225,000 380,000 Climate change and the carbon economy Malaria & Vector Borne Diseases 20,000 20,000 are already significantly higher Meningitis 30,000 40,000 than the estimated costs of Environmental Disasters 5,000 7,000 shifting the world economy to Air Pollution 1,400,000 2,100,000 a low-carbon footing – around Indoor Smoke 3,100,000 3,100,000 0.5% of GDP for the current Carbon decade, although increasing for Occupational Hazards 55,000 80,000 subsequent decades.1 Skin Cancer 20,000 45,000 This report and scientific World 4,975,000 5,957,000 literature imply adaptation costs 18 I EXECUTIVE SUMMARY share of the global population would be directly pronounced vulnerabilities resulting from climate to be at least 150 billion dollars affected by inaction on climate change. change: sub-Saharan Africa, small island developing per year today for developing Global figures mask enormous costs that will, in states, and South Asia in particular. countries, rising to a minimum particular, hit developing countries and above all the Poverty reduction efforts are in peril as the potential of more than 1 trillion dollars world’s poorest groups. Least Developed Countries temperature increase the world is already committed per year by 2030. These costs (LDCs) faced on average in excess of 7% of forgone to has only begun to be realized, and the world’s are, however, considerably GDP in 2010 due to climate change and the carbon major economies are in no way spared. The United lower than costs of damages to economy, as all faced inequitable access to energy States, China and India in particular are expected developing countries estimated and sustainable development. to incur enormous losses that in 2030 for these here, so adapting to climate Over 90% of mortality assessed in this report occurs three countries alone will collectively total 2.5 trillion change is very likely a cost- in developing countries only – more than 98% in the dollars in economic costs and over 3 million deaths effective investment in almost case of climate change. per year, or half of all mortality – the majority in India all cases and should be central Of all these losses, it is the world’s poorest and China. to any climate change policy. communities within lower and middle-income The whole world is affected by these comprehensive Beyond adaptation, this report countries that are most exposed. Losses of income concerns: 250 million people face the pressures also emphasizes the urgency among these groups is already extreme. The world’s of sea-level rise; 30 million people are affected of mitigating key risks: tackling principal objectives for poverty reduction, the by more extreme weather, especially flooding; food security, indoor fires/ Millennium Development Goals (MDGs), are therefore 25 million people are affected by permafrost smoke, air pollution and other under comprehensive pressures, in particular as a thawing; and 5 million people are pressured by health issues such as diarrheal result of climate change. desertification. The pressures that these combined illnesses, malaria and meningitis The impact for rural and coastal communities in stresses put on affected communities are immense that are all urgent priorities the lowest-income settings implies serious threats and force or stimulate the movement of populations. for lessening the extent of the for food security and extreme poverty (goal 1 As is highlighted in the Ghana country study in this human toll of this crisis. of 8), child health and the ability of children to report, they can also fuel violence and an erosion of With costs due both to attend school (goals 2 and 4), maternal health the social and economic fabric of communities. unabated climate change and women’s development (goals 3 and 5), the The impact of climate change on Labour Productivity and the carbon economy prevalence of infectious diseases (goal 6) and, is assessed here as the most substantial economic expected to rise rapidly over through water, fisheries and biodiversity impacts, loss facing the world as a result of climate change. A the course of this century, environmental sustainability (goal 7). Furthermore, large proportion of the global workforce is exposed tackling climate change by in a difficult fiscal environment, the advent of to the incessant increase in heat, with the number of reducing emissions yields net climate change has pressured governments to divert very hot days and nights increasing in many places benefits to the world economy Official Development Assistance (ODA) funds from by 10 days a decade.2 Developing countries, and in monetary terms – amounting other development commitments and activities in especially the lowest-income communities, are highly to around a 1% higher GDP an attempt to provide support for climate change vulnerable to these effects because of geographical for the entirety of the 21st concerns, including to a marginal degree, for location – northern countries like Scandinavia, it is century (net present value at helping vulnerable communities adapt to climate assumed, benefit from improved labour productivity a 3% discount rate). World change. The Green Climate Fund, agreed upon due to warmer weather – but also because their net benefits from action on in incrementally greater detail at the successive labour forces have the highest proportion of non- climate change are insensitive international climate talks at Copenhagen, Cancún climate controlled occupational environments.3 to discount rates from 0.1% and Durban, faces an economic environment of Global productivity in labour is surging due to to 20% (the highest tested). declining ODA tied to acute fiscal crises across technological advances and a shift of emphasis from Even the most ambitious a host of the world’s wealthiest economies (see: agricultural activities to an industrial and service reductions in emissions aimed climate finance). These developments have sector focus for most developing countries, among at holding warming below 2ºC 4 ultimately compromised the global partnership other key developments. Climate change, however, (e.g. 400ppm CO2e/IPCC AR5 for development (goal 8). Lag areas towards MDG holds back the full extent of productivity gains RCP2.6 scenario) generates achievement also align very closely with the most the world would otherwise enjoy.5 In this way, the economic benefits for the EXECUTIVE SUMMARY I 19 costs of climate change are hidden, which helps to registered in many developing regions of the world, world economy after accounting explain in part how their full extent may have been in particular for sub-Saharan Africa and the Pacific.6 for the costs of reducing emissions missed. Even so, not all have benefitted from fast Not one country is invulnerable to the combined (mitigation costs). Limiting warming expanding labour productivity: labour productivity is effects of climate change and the carbon economy. to this level would limit human, a core indicator for MDG 1 (on extreme poverty and Inaction on climate change penalizes every country territorial and ecological damage hunger), for instance, where little progress has been in the world, just as all are set to gain from action as well as other concerns, such as climate-induced forced movement MULTI-DIMENSIONAL VULNERABILITY of human populations. CLIMATE Over 98% of all climate change mortality and over 90% of all carbon economy related mortality is in developing countries: between 80% and 90% of all economic costs are projected to fall on developing countries. The most extreme effects of climate change are estimated to be felt by the Least Developed Countries, with average GDP losses of 8% in 2030. With respect to carbon economy effects, inequitable access to sustainable development sees Least Developed Countries again incurring the highest relative losses at over 3% of GDP, while between two thirds and three quarters of all carbon economy costs are borne by developing countries. When the costs of climate change CARBON and the carbon economy estimated here are combined, not one country in the world is left unharmed. In terms of regional incentives to tackle climate change, every region is estimated to experience net economic benefits from action on climate change even for the highest levels of action. The Monitor only analyses incremental impacts as a result of climate change, or changes in the frequency of well-known stochastic events, such as floods and landslides. Not assessed here in any way are potential catastrophic impacts that could occur due to Acute Severe High Moderate Low more rapid climate change fuelled 20 I EXECUTIVE SUMMARY on climate change. Moreover, the vulnerability of There are, however, limits to the ability of by feedbacks such as a release the world is shifting with every passing decade. populations to adapt. The oceans can hardly be of Arctic methane deposits, more Countries once resilient to marginal weather effects refrigerated against marine stresses.9 Desert rapid sea-level rise that could result increasingly realize susceptibilities to a changed encroachment can be prevented but rarely reversed, from the disintegration of the West climate as the increase in heat and associated and if so, generally at great expense.10 It might be Antarctic Ice Sheet or large-scale effects continue to reach new extremes. possible to protect a beach, but concrete polders climatic disruptions such as the Some quite serious damage is now unavoidable, could well be to the detriment of an area’s authentic collapse of ocean circulation but certain losses can still be reduced in the short charm and so to the value of properties. mechanisms, all of which are term. In particular, human costs can be transferred A low-carbon, renewable economy – of hydro, wind, understood to pose significantly to economic costs. This can be achieved through solar, geothermal, tidal and other innovative sources of larger human, economic and programmes aimed at reducing rural poverty – at the energy – now competes with the most carbon-intensive ecological risks than anything origin of hunger deaths and many communicable forms of power generation in the open market, where portrayed here. The possibilities diseases afflicting the world’s poorest groups, with they constitute around 10% of the global energy mix of these events are by no means risks that worsen with climate change. Or it can be today.11 Shifting the balance in favour of low-carbon ruled out, with risks increasing achieved by ensuring clean air regulations, safer energy has been estimated to cost approximately 0.5% substantially with warming.2 Other working conditions and modern energy options for or less of GDP for the current decade.12 economists have therefore factored people at risk due to carbon-intensive forms of energy. The carbon economy is largely responsible for such risks into their economic All these measures will save lives but cost money. the incredible growth in overall wealth society analysis to a degree.3 Economic losses themselves can also be lessened. A has amassed over the last 200 years, although, Only with the deep and sustained major recent review of humanitarian assistance work according to the World Bank, 1.3 billion people emissions reductions spelled out noted that Mozambique had requested 3 million continue to remain trapped in dire poverty.13 in the lowest of the new IPCC RCP dollars from the international community for flood Regardless, an economic system developed to 2.6 scenario is there a reasonable preparations. That sum went unsecured, and 100 support a global population of 1 or 2 billion people chance (comfortably over 50%) of million dollars was subsequently spent on emergency in the 19th century is ill suited to a global population not exceeding the internationally flood response.7 Investment in agriculture might in excess of 7 billion and growing.14 accepted “safety” temperature also be cost-effective if the costs of supporting The climate challenge runs in parallel to other key threshold of 2ºC global mean upgraded farming were to generate more benefits (in global developments: a growing world population, warming above preindustrial.4 Given productivity, output) than the initial outlay.8 a major propensity to urbanization, and structural the clear human, ecological and, ** REGIONAL COST BENEFIT ANALYSIS, 2010-2100 PERCENTAGE OF GLOBAL GDP (NOMINAL), NET PRESENT VALUE AT 3% DISCOUNT RATE Climate + Carbon Costs Highest Action High Action Moderate Action Net Benefit Highest High Moderate No action action action Avoided Mitigation Avoided Mitigation Avoided Mitigation Highest High Moderate Region Action (400 (450 (550 costs* costs costs* costs costs* costs action Action action ppm) ppm) ppm) USA 3.0% 1.0% 1.0% 1.5% 2.0% 1.5% 2.0% 1.0% 1.5% 0.5% 0.5% 1.0% 1.0% Japan 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.0% 0.0% 0.0% Russia 4.5% 1.5% 1.5% 2.0% 3.0% 2.0% 3.0% 2.0% 2.5% 2.5% 1.0% 1.0% 0.0% China 4.5% 2.0% 2.0% 2.5% 2.5% 2.0% 2.5% 1.5% 2.0% 1.0% 0.5% 1.0% 1.0% India 11.0% 5.0% 5.5% 6.5% 6.0% 3.0% 5.5% 2.0% 4.5% 0.5% 3.0% 3.5% 4.0% EU27 1.0% 0.5% 0.5% 0.5% 0.5% 1.0% 0.5% 0.5% 0.5% 0.5% 0.0% 0.0% 0.0% ROW 8.5% 3.5% 3.5% 4.5% 5.5% 2.0% 5.0% 1.0% 4.5% 0.5% 3.5% 4.0% 3.5% World*** 4.0% 1.5% 1.5% 2.0% 2.5% 1.5% 2.0% 1.0% 2.0% 0.5% 1.0% 1.0% 1.0% *Avoided costs: No action (A1B +8.5 ) minus reduced ppm scenario (400 ppm C02e: RCP2.6; 450 ppm: RCP2.9; 550 ppm: SRES B1) ** Discounted (3%) sum of costs and GDP – mitigation costs from Edenhofer et al., 2010 (regional: Remind + Poles) *** Median value of all 5 scenarios (Edenhofer et al., 2010) EXECUTIVE SUMMARY I 21 ACTION VERSUS INACTION OVER THE 21ST CENTURY 21ST CENTURY COSTS OF CLIMATE CHANGE ACTION, INACTION AND MITIGATION NPV OF GLOBAL CLIMATE/CARBON COSTS AND MITIGATION COSTS RELATIVE TO GDP PERCENTAGE (%) OF NOMINAL GDP NON-DISCOUNTED (NOMINAL 2010-2100, 3% DISCOUNT RATE) 8% 5% 7% 4% 6% 1.8% 5% 3% 1.1% 4% 2% 3% 2.1% 0.4% 2% 1% 1.3% 1% 0 0% ACTION NO ACTION 2000 2010 2020 2030 2040 205020602070 2080 2090 2100 MITIGATION COST CARBON COST CLIMATE COST NO ACTION ACTION MITIGATION Action equals 450 ppm (RCP 2.9) No action equals mid-point of 2 non-stabilization scenarios (RCP 8.5 and SRES A1B) shifts occurring in economies around the world. differs little in fundamental terms from the global ultimately, economic advantages of All of these tendencies – most pronounced in analysis: all regions benefit from climate action in aiming for a highest-action scenario, developing countries, in particular the process of economic terms. Most regions find optimal climate this report’s findings imply that industrialization now spreading more and more action in the high-action scenario. The highest the highest action targets would widely15 – can worsen or attenuate vulnerabilities to action to reduce emissions also limits the risks reap the most benefits for the climate change or the carbon economy. of crossing tipping points leading to large-scale world. Therefore, the highest-action In order to understand the fuller implications of this climate disruptions.16 Less ambitious action on scenario is recommended to policy study and to make its findings comparable with climate change does not: moderate action on makers as the preferred target for previous works that take on longer-term perspectives, climate change has a high chance of exceeding the enhancing and safeguarding global the costs of climate change and the carbon economy accepted international temperature goal of holding prosperity. Mainstream economic were also estimated for the period up until 2100. On warming below 2° C (3.6° F) above pre-industrial modelling shows that this transition this basis, business-as-usual development could see levels.17 The most vulnerable countries have called is technologically and economically the costs of inaction exceeding 10% of global GDP in for warming to be limited below 1.5° C above feasible but that action is needed losses prior to 2100. pre-industrial levels as they believe 2° C is far too now to get onto this pathway.5 Reducing emissions results in net benefits for society damaging and a risk to their survival. International cooperation will clearly in every case because the costs of a low-carbon Neither should the risks of catastrophic impacts be be central to ensuring that the costs transition are more than outweighed by averted losses discarded as heresy: new research has highlighted of the transition are maintained at due to climate change and the carbon economy. great risks associated with heat, as opposed to the lowest most efficient level and In the global context, the highest level of emission ocean-related immersion of countries, with heat that the transition yields the highest reductions results in similar global benefits to risks concerning far greater shares of the world co-benefits.6 lower levels of action. However, the highest action economy and its population. In particular, at certain sees fewer negative impacts on society –from levels of high-end warming, large areas of the planet 1 See: Edenhofer et al., 2010; IPCC, 2012a human health to biodiversity and for the world’s would progressively begin to exceed the thermal 2 Weitzman, 2007; Hare in Mastny, 2009 3 For example: Hope, 2006; Stern, 2006 oceans – but requires slightly greater investments maximum at which human beings are able to survive 4 Pope et al., 2010 in low-emission forms of energy. Less ambitious outdoors.18 The possibilities of very rapid climate 5 For an overview of some leading mitigation scenarios, see: Edenhofer et action means accepting larger scales of human and change are not implausible or ruled out by climate al., 2010; UNEP, 2011; IPCC, 2012a ecological impacts. change models, especially as the planet warms 6 For example the economic benefits of cross-border emission reduction The regional analysis of costs and benefits beyond the 2 degrees Celsius temperature threshold cooperation: De Cian and Tavoni, 2010 22 I EXECUTIVE SUMMARY the international community has set for itself.19 Of action on climate change is the savviest choice both 1 Hansen et al., 2005 2 Kjellstrom et al., 2009a; McSweeney particular long-term concern are 1500 gigatonnes of in monetary, humanitarian and environmental terms. et al., 2012 CO (GtCO ) of methane stored in frozen sediments The highest-action approach is the pathway that the 3 ILO LABORSTA, 2012 2 2 4 Storm and Naastepad, 2009; Wacker et al., in the East-Siberian Sea at depths of less than 40 analysis in this report most supports. 2006; Restuccia, et al., 2004; Storm and 20 Naastepad, 2009; McMillan and Rodrik, to 50 metres. This represents three times the The world risks carbon lock-in due to high-intensity 2012 5 amount of CO2 that could be released over much of carbon infrastructure plans still moving forward in Kjellstrom et al., 2009a-b this century if the 2 degrees target is to be kept.21 As the near term, so the shift in focus to a low-carbon 6 UN, 2012 7 Ashdown et al., 2011 the Arctic sea warms due to climate change, these transition should likely occur prior to 2017 and 8 Parry et al., 2009; EACC, 2010 sediments are thawing and methane is already being continue aggressively thereafter.23 Several major 9 Cheung et al., 2010 10 visibly released at rates that currently exceed the economies will need to adjust and enact important Puigdefaabregas, 1998 11 US EIA, 2011 total amount of methane emitted through natural domestic policy and legislative initiatives in order 12 Edenhofer et al., 2010; IPCC, 2012b processes over the entirety of the world’s oceans.22 to make this a reality. Whatever the case, action 13 Chen and Ravallion, 2012 14 World Population Prospects/UN DESA, 2011 While all policy pathways for reducing emissions on climate change that seeks out international 15 OECD, 2012; IMF WEO, 2012; World have similar net benefits in economic terms, the partnership is most likely to further lessen the costs Population Prospects/UN DESA, 2011 16 Pope et al., 2010 highest-action route would clearly reap the greatest of a low-carbon transition and expand the benefits of 17 UNFCCC, 2009 human, societal, economic and environmental this transition for all concerned. This report documents 18 Sherwood and Huber, 2010 benefits, since it would ensure the greatest chances in part the potential benefits of avoided impacts of 19 Wietzman, 2007 20 Shakhova et al., 2008 of avoiding climate-triggered catastrophe and would climate change in addition to the potential co-benefits 21 Meinshausen et al., 2009 minimize the human, social and environmental of emission reductions that are targeted at key 22 Shakhova et al., 2008 and 2010 23 24 IAE, 2011; UNEP, 2011 impacts of a hotter planet. Therefore, the cold economic, health and environmental concerns. 24 De Cian and Tavoni, 2010 calculus of a hot planet implies the most ambitious CLIMATE+CARBON CLIMATE 2030 54 2030 67 ACUTE ACUTE 2010 21 2010 20 2030 31 2030 21 SEVERE SEVERE 2010 27 2010 38 2030 38 2030 20 HIGH HIGH 2010 59 2010 24 2030 55 2030 31 MODERATE MODERATE 2010 73 2010 44 2030 6 2030 45 LOW LOW 2010 4 2010 58 = 5 countries (rounded) EXECUTIVE SUMMARY I 23 SUMMARY OF ECONOMIC IMPACT 2010 2030 LOSSES GAINS NET 2030 NET 2010 2010 2010 DROUGHT 1844**21*41131 FLOODS & LANDSLIDES 941010*261*216653 STORMS 1001515*237*166420* WILDFIRES **** ******** TOTAL 213 29 29 * 5 14 10 1 40 142 28 4 BIODIVERSITY 389 78 78 * 8 26 36 9 56 299 80 54 DESERTIFICATION 2045***215466 HEATING & COOLING -77 -33 5 -38 1 2 24 -8 30 7 -65 -49 LABOUR PRODUCTIVITY 2,400 311 314 -3 135 162 16 -1 1,035 1,364 49 -12 PERMAFROST 153 31 31 * 1 10 3 17 5 68 5 75 SEA-LEVEL RISE 526 86 86 * 23 42 15 5 166 310 29 22 CLIMATE WATER 13 14 44 -30 3 -3 13 7 -21 45 39 39 TOTAL 3,461 491 563 -71 166 235 60 30 1,276 1,908 144 135 TOTAL 106 23 23 * 17 5 * 0.5 84 21 * 1 AGRICULTURE 367 50 51 * 27 17 3 2 208 144 8 10 FISHERIES 168 13 16 -3 7 7 1 -1 97 80 -3 -6 FORESTRY 4467-1*4**93411 HYDRO ENERGY -24 -4 * -4 * -3 * * 3 -20 -1 * TOURISM * * 5 -5 2 * -1 * 19 -16 -2 -1 TRANSPORT 711* **1**16* TOTAL 565 66 80 -13 37 25 2 2 329 223 8 5 TOTAL GLOBAL RESULTS 4,345 609 695 -84 225 279 72 33 1,730 2,294 179 144 OIL SANDS 2477***7*21200.5 OIL SPILLS 381313*1660.532492 TOTAL 61 20 20 * 1 6 13 0.5 5 25 29 3 BIODIVERSITY 1,734 291 291 * 32 128 114 17 236 1,034 349 115 CORROSION 5 1.5 1.5 * * 0.5 0.5 * 1 4 0.5 0.5 WATER 1044***31*244 TOTAL 1,749 296 296 * 32 129 117 18 238 1,038 353 120 CARBON TOTAL 630 172 172 * 74 67 21 10 226 341 37 26 AGRICULTURE -1711517-21294-58-121 4 4 FISHERIES 77 9 9 * 1 7 0.5 * 5 70 2 0.5 FORESTRY 83 28 28 * 3 9 14 1 13 48 18 4 TOTAL -115254-2418245-40-3248 TOTAL GLOBAL RESULTS 2,429 540 542 * 112 220 174 34 429 1,401 444 156 * Less than one billion dollars Billions of dollars (2010 PPP) Environmental disasters Habitat change Health impact Industry stress non-discounted. Totals do not correspond exactly due to rounding. Developing Country Low Emitters Developing Country High Emitters Developed Other Industrialized Exhibit 7 Fracking by the Numbers Key Impacts of Dirty Drilling at the State and National Level Fracking by the Numbers Key Impacts of Dirty Drilling at the State and National Level Written by: Elizabeth Ridlington Frontier Group John Rumpler Environment America Research & Policy Center October 2013 Acknowledgments Environment America Research & Policy Center sincerely thanks John Amos of SkyTruth, Anthony Ingraffea, Ph.D., P.E., and Kari Matsko, Director of People’s Oil & Gas Collaborative-Ohio for their review of drafts of this document, as well as their insights and suggestions. Tareq Alani, Spencer Alt, Elise Sullivan and Anna Vanderspek provided valuable research assistance. Thanks also to Travis Madsen of Frontier Group for technical assistance, and Tony Dutzik and Benjamin Davis of Frontier Group for editorial help. We also are grateful to the many state agency staff who answered our numerous questions and requests for data. Many of them are listed by name in the methodology. Environment America Research & Policy Center thanks the V. Kann Rasmussen Foundation and the Park Foundation for making this report possible. The authors bear responsibility for any factual errors. The recommendations are those of Environment America Research & Policy Center. The views expressed in this report are those of the authors and do not necessarily reflect the views of our funders or those who provided review. © 2013 Environment America Research & Policy Center Environment America Research & Policy Center is a 501(c)(3) organization. We are dedicated to protecting our air, water and open spaces. We investigate problems, craft solutions, educate the public and decision- makers, and help the public make their voices heard in local, state and national debates over the quality of our environment and our lives. For more information about Environment America Research & Policy Center or for additional copies of this report, please visit www.environmentamericacenter.org. Frontier Group conducts independent research and policy analysis to support a cleaner, healthier and more democratic society. Our mission is to inject accurate information and compelling ideas into public policy debates at the local, state and federal levels. For more information about Frontier Group, please visit www.frontiergroup.org. Layout: To the Point Publications, www.tothepointpublications.com Cover photo: Peter Aengst via SkyTruth/EcoFlight Table of Contents Executive Summary ...... 4 Introduction ...... 7 Fracking Poses Grave Threats to the Environment and Public Health 8 Contaminating Drinking Water ...... 9 Consuming Scarce Water Resources ...... 11 Endangering Public Health with Air Pollution ...... 12 Exacerbating Global Warming ...... 14 Damaging America’s Natural Heritage ...... 14 Imposing Costs on Communities ...... 16 Quantifying the State and National Impacts of Fracking ...... 19 Wells Fracked by State ...... 20 Wastewater Produced ...... 20 Chemicals Used ...... 22 Water Used ...... 22 Air Pollution Created ...... 23 Global Warming Pollution Released ...... 24 Acres of Land Damaged ...... 25 Policy Recommendations ...... 27 Methodology ...... 29 Notes ...... 41 Executive Summary ver the past decade, the oil and gas indus- To protect our states and our children, states should try has fused two technologies—hydrau- halt fracking. lic fracturing and horizontal drilling—in Toxic wastewater: Fracking produces Oa highly polluting effort to unlock oil and gas in underground rock formations across the United enormous volumes of toxic States. wastewater—often containing cancer- causing and even radioactive material. As fracking expands rapidly across the country, Once brought to the surface, this toxic there are a growing number of documented cases waste poses hazards for drinking of drinking water contamination and illness among water, air quality and public safety: nearby residents. Yet it has often been difficult for • Fracking wells nationwide produced an estimated the public to grasp the scale and scope of these 280 billion gallons of wastewater in 2012. and other fracking threats. Fracking is already underway in 17 states, with more than 80,000 wells • This toxic wastewater often contains cancer- drilled or permitted since 2005. Moreover, the oil causing and even radioactive materials, and and gas industry is aggressively seeking to expand has contaminated drinking water sources from fracking to new states—from New York to Califor- Pennsylvania to New Mexico. nia to North Carolina—and to areas that provide drinking water to millions of Americans. • Scientists have linked underground injection of wastewater to earthquakes. This report seeks to quantify some of the key impacts of fracking to date—including the produc- • In New Mexico alone, waste pits from all oil and tion of toxic wastewater, water use, chemicals use, gas drilling have contaminated groundwater on air pollution, land damage and global warming more than 400 occasions. emissions. Table ES-1. National Environmental and Public Health Impacts of Fracking Fracking Wells since 2005 82,000 Toxic Wastewater Produced in 2012 (billion gallons) 280 Water Used since 2005 (billion gallons) 250 Chemicals Used since 2005 (billion gallons) 2 Air Pollution in One Year (tons) 450,000 Global Warming Pollution since 2005 (million metric tons CO2-equivalent) 100 Land Directly Damaged since 2005 (acres) 360,000 4 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Water use: Fracking requires huge Air pollution: Fracking-related volumes of water for each well. activities release thousands of tons of • Fracking operations have used at least 250 billion health-threatening air pollution. gallons of water since 2005. (See Table ES-2.) • Nationally, fracking released 450,000 tons of pollutants into the air that can have immediate • While most industrial uses of water return it to the health impacts. water cycle for further use, fracking converts clean water into toxic wastewater, much of which must • Air pollution from fracking contributes to the then be permanently disposed of, taking billions of formation of ozone “smog,” which reduces lung gallons out of the water supply annually. function among healthy people, triggers asthma attacks, and has been linked to increases in • Farmers are particularly impacted by fracking water school absences, hospital visits and premature use as they compete with the deep-pocketed oil and death. Other air pollutants from fracking and the gas industry for water, especially in drought-stricken fossil-fuel-fired machinery used in fracking have regions of the country. been linked to cancer and other serious health effects. Chemical use: Fracking uses a wide range of chemicals, many of them toxic. Global warming pollution: Fracking • Operators have hauled more than 2 billion gallons produces significant volumes of of chemicals to thousands of fracking sites around global warming pollution. the country. • Methane, which is a global warming pollutant • In addition to other health threats, many of these 25 times more powerful than carbon dioxide, chemicals have the potential to cause cancer. is released at multiple steps during fracking, including during hydraulic fracturing and well • These toxics can enter drinking water supplies from completion, and in the processing and transport leaks and spills, through well blowouts, and through of gas to end users. the failure of disposal wells receiving fracking wastewater. • Global warming emissions from completion of fracking wells since 2005 total an estimated 100 Table ES-2. Water Used for Fracking, Selected million metric tons of carbon dioxide equivalent. States Damage to our natural heritage: Well Total Water Used since pads, new access roads, pipelines and State 2005 (billion gallons) other infrastructure turn forests and Arkansas 26 rural landscapes into industrial zones. Colorado 26 • Infrastructure to support fracking has damaged New Mexico 1.3 360,000 acres of land for drilling sites, roads and North Dakota 12 pipelines since 2005. Ohio 1.4 • Forests and farmland have been replaced by well Pennsylvania 30 pads, roads, pipelines and other gas infrastruc- Texas 110 ture, resulting in the loss of wildlife habitat and West Virginia 17 fragmentation of remaining wild areas. Executive Summary 5 • In Colorado, fracking has already damaged To address the environmental and 57,000 acres of land, equal to one-third of the public health threats from fracking acreage in the state’s park system. across the nation: • The oil and gas industry is seeking to bring • States should prohibit fracking. Given the fracking into our national forests, around sever- scale and severity of fracking’s myriad impacts, al of our national parks, and in watersheds that constructing a regulatory regime sufficient to supply drinking water to millions of Americans. protect the environment and public health from dirty drilling—much less enforcing such Fracking has additional impacts not quantified safeguards at more than 80,000 wells, plus here—including contamination of residential processing and waste disposal sites across the water wells by fracking fluids and methane leaks; country—seems implausible. In states where vehicle and workplace accidents, earthquakes and fracking is already underway, an immediate other public safety risks; and economic and social moratorium is in order. In all other states, banning damage including ruined roads and damage to fracking is the prudent and necessary course to nearby farms. protect the environment and public health. • Given the drilling damage that state officials have allowed fracking to incur thus far, at a minimum, Defining “Fracking” federal policymakers must step in and close the In this report, when we refer to the impacts loopholes exempting fracking from key provisions of “fracking,” we include impacts resulting of our nation’s environmental laws. from all of the activities needed to bring a shale gas or oil well into production • Federal officials should also protect America’s using high-volume hydraulic fracturing natural heritage by keeping fracking away from (fracturing operations that use at least our national parks, national forests, and sources of 100,000 gallons of water), to operate that drinking water for millions of Americans. well, and to deliver the gas or oil produced • To ensure that the oil and gas industry—rather from that well to market. The oil and gas than taxpayers, communities or families—pays industry often uses a more restrictive the costs of fracking damage, policymakers should definition of “fracking” that includes only require robust financial assurance from fracking the actual moment in the extraction operators at every well site. process when rock is fractured—a definition that obscures the broad changes • More complete data on fracking should be collect- to environmental, health and community ed and made available to the public, enabling conditions that result from the use of us to understand the full extent of the harm that fracking in oil and gas extraction. fracking causes to our environment and health. 6 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Introduction any Americans have an image of the sources of information on the extent of fracking and damage caused by fracking. Documen- the impacts of fracking on our environment and taries and YouTube videos have shown health. Mus tap water catching on fire and families experienc- Our analysis shows that damage from fracking is ing headaches, dizziness, nausea and other illnesses widespread and occurs on a scale unimagined just a while living near fracking operations. Plane trips over few years ago. Moreover, three factors suggest that Texas or Colorado reveal the grids of wells across the the total damage from fracking is far worse than we landscape. have tabulated here. Severe limitations in available These snapshots illustrate the damage that frack- data constrain our ability to see the full extent of ing does to the environment and our health. But, the damage. Second, there are broad categories until now, it has been difficult to comprehend the of fracking damage—such as the number of water cumulative extent of that damage. Individual frack- wells contaminated—that would be difficult to ing wells, we know, can pollute the air and water of a ascertain under any circumstances. Finally, there neighborhood or town. But what does it mean now remain major gaps in the scientific community’s un- that the nation has not dozens or hundreds but tens derstanding of issues such as the long-term conse- of thousands of fracking wells in at least 17 states? quences of pumping toxic fluids into the ground. What, for example, is the magnitude of the risk those Even the limited data that are currently available, wells present to drinking water? How many iconic however, paint an increasingly clear picture of the landscapes are being damaged? damage that fracking has done to our environment In this report, we have quantified several of the key and health. It will take decisive action to protect the impacts of fracking on water, air and land, at the American people and our environment from the state and national level, using the best available damage caused by dirty drilling. Our analysis shows that damage from fracking is widespread and occurs on a scale unimagined just a few years ago. Introduction 7 Fracking Poses Grave Threats to the Environment and Public Health ver the past decade, the oil and gas indus- Roughly half of U.S. states, stretching from New York try has used hydraulic fracturing to extract to California, sit atop shale or other rock formations oil and gas from previously inaccessible with the potential to produce oil or gas using frack- Orock formations deep underground. The use of high- ing. (See Figure 1.) volume hydraulic fracturing—colloquially known Fracking has unleashed a frenzy of oil and gas drilling as “fracking”—has expanded dramatically from its in several of these shale formations—posing severe origins in the Barnett Shale region of Texas a decade threats to the environment and public health. ago to tens of thousands of wells nationwide today. Figure 1. Shale Gas and Oil Plays1 Lower 48 states shale plays Niobrara* Montana Thrust Bakken*** Belt Heath** Cody Williston Basin Big Horn Powder River Gammon Hilliard- Basin Basin Baxter- Mowry Appalachian Mancos Michigan Basin Greater Basin Antrim Green Niobrara* River Park Forest Basin Basin Devonian (Ohio) City Basin Illinois Uinta Basin Marcellus Basin Manning Utica Canyon San Joaquin Piceance Denver Basin Mancos Basin Basin Excello- New Hermosa Mulky Cherokee Platform Albany Monterey- Paradox Basin Pierre Temblor Lewis Raton Woodford San Juan Anadarko Fayetteville Basin Basin Chattanooga ArdBasin Monterey mo Arkoma Basin Black Warrior Palo Duro re Santa Maria, Bend Ba Basin Conasauga Basin sin Ventura, Los Floyd- Valley & Ridge Angeles Avalon- Neal Province Basins Bone Spring Permian Barnett TX-LA-MS Miles Basin Ft. Worth Salt Basin Barnett- Marfa Basin Tuscaloosa 0 100 200 300 400 Woodford Basin Eagle Haynesville- Ford Bossier ± Pearsall Western Shale plays BasinBsasins Gulf Current plays * Mixed shale & Prospective plays chalk play ** Mixed shale & Stacked plays limestone play Shallowest/ youngest ***Mixed shale & Intermediate depth/ age tight dolostone- Deepest/ oldest siltstone-sandstone Source: Energy Information Administration based on data from various published studies. Updated: May 9, 2011 8 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Contaminating Drinking Water blowouts can release polluted water to groundwater and surface water. For example, in September 2009 Fracking has polluted both groundwater and surface Cabot Oil and Gas caused three spills in Dimock waterways such as rivers, lakes and streams. Fracking Township, Pennsylvania, in less than a week, dump- pollution can enter our waters at several points in the ing 8,000 gallons of fracturing fluid components into process—including leaks and spills of fracking fluid, Stevens Creek and a nearby wetland.7 well blowouts, the escape of methane and other contaminants from the well bore into groundwater, and the long-term migration of contaminants under- Leaks of Methane and Other ground. Handling of toxic fracking waste that returns Contaminants from the Well Bore to the surface once a well has been fracked presents A study by researchers at Duke University found more opportunities for contamination of drinking that the proximity of drinking water wells to frack- water. State data confirm more than 1,000 cases of ing wells increases the risk of contamination of water contaminated by dirty drilling operations. For residential wells with methane in Pennsylvania. The example: researchers pointed to faulty well casing as a likely source.8 Data from fracking wells in Pennsylvania • In Colorado, approximately 340 of the leaks or from 2010 to 2012 show a 6 to 7 percent well failure spills reported by drilling operators engaged in all rate due to compromised structural integrity.9 types of oil and gas drilling over a five-year period polluted groundwater;2 Migration of Contaminants • In Pennsylvania, state regulators identified 161 A recent study of contamination in drinking water instances in which drinking water wells were wells in the Barnett Shale area of North Texas found impacted by drilling operations between 2008 and arsenic, selenium and strontium at elevated levels 3 the fall of 2012; and in drinking water wells close to fracking sites.10 The researchers surmise that fracking has increased pol- • In New Mexico, state records show 743 instances lution in drinking water supplies by freeing naturally of all types of oil and gas operations polluting available chemicals to move into groundwater at groundwater—the source of drinking water for 90 higher concentrations or through leaks from faulty percent of the state’s residents.4 well construction. Spills and Leaks of Fracking Fluids Toxic Fracking Waste Toxic substances in fracking chemicals and wastewa- The wastewater produced from fracking wells ter have been linked to a variety of negative health contains pollutants both from fracking fluids and effects on humans and fish. Chemical components from natural sources underground. It returns to the of fracking fluids, for example, have been linked to surface in huge volumes—both as “flowback” im- cancer, endocrine disruption and neurological and mediately after fracking and “produced water” over immune system problems.5 Wastewater brought to a longer period while a well is producing oil or gas. the surface by drilling can contain substances such as Yet fracking operators have no safe, sustainable way volatile organic compounds with potential impacts of dealing with this toxic waste. The approaches that on human health.6 drilling companies have devised for dealing with There are many pathways by which fracking fluids wastewater can pollute waterways through several can contaminate drinking water supplies. Spills from avenues. trucks, leaks from other surface equipment, and well Fracking Poses Grave Threats to the Environment and Public Health 9 • Waste pits can fail. In New Mexico, substances bromide in the wastewater mixes with chlorine from oil and gas pits have contaminated ground- (often used at drinking water treatment plants), it water at least 421 times.11 Moreover, waste pits produces trihalomethanes, chemicals that cause also present hazards for nearby wildlife and cancer and increase the risk of reproductive or livestock. For example, in May 2010, when a developmental health problems.14 Pennsylvania fracturing wastewater pit owned by East Resources leaked into a farm field, the state • Drilling companies deliberately spread wastewa- Department of Agriculture was forced to quaran- ter on roads and fields. Pollutants from the water tine 28 cattle exposed to the fluid to prevent any can then contaminate local waterways. Drilling contaminated meat from reaching the market.12 operators sometimes spray wastewater on dirt and gravel roads to control dust, or on paved • Discharge of fracking wastewater into rivers can roads to melt ice. In some Western states, frack- pollute drinking water supplies. For example, after ing waste is spread on farmland or used to water water treatment plants discharged fracking waste- cattle.15 water into the Monongahela River, local authori- ties issued a drinking water advisory to 350,000 • Deep disposal wells are a common destination for people in the area.13 In addition, fracking waste- fracking waste, but these wells can fail over time, water discharged at treatment plants can cause allowing the wastewater and its pollutants to mix 16 a different problem for drinking water: when with groundwater or surface water. For example, Photo: The Downstream Project via SkyTruth/LightHawk. Fracking wastewater is often stored in open waste pits such as these, near Summit, Pennsylvania. Leaks from pits can contaminate drinking water supplies. 10 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level wastewater injected into a disposal well contami- use, fracking converts clean water into toxic waste- nated the Cenozoic Pecos Alluvium Aquifer with water, much of which must then be permanently 6.2 billion gallons of water near Midland, Texas.17 disposed of, taking billions of gallons out of the In Pennsylvania, a disposal well in Bell Township, water supply annually. Moreover, farmers are particu- Clearfield County, lost mechanical integrity in April larly impacted by fracking water use, as they must 2011, but the operator, EXCO Resources, contin- now compete with the deep-pocketed oil and gas ued to inject fracking wastewater into the well industry for water, especially in the drought-stricken for another five months.18 The U.S. Environmental regions of the country. Protection Agency (EPA) fined the company nearly In some areas, fracking makes up a significant share $160,000 for failing to protect drinking water of overall water demand. In 2010, for example, frack- supplies. Nationally, routine testing of injection ing in the Barnett Shale region of Texas consumed wells in 2010 revealed that 2,300 failed to meet an amount of water equivalent to 9 percent of the mechanical integrity requirements established by city of Dallas’ annual water use.21 An official at the the EPA.19 Texas Water Development Board estimated that one • Pressure from injection wells may cause under- county in the Eagle Ford Shale region will see the ground rock layers to crack, accelerating the share of water consumption devoted to fracking and migration of wastewater into drinking water similar activities increase from zero a few years ago aquifers. For example, at two injection wells in to 40 percent by 2020.22 Unlike other uses, water used Ohio, toxic chemicals pumped underground in in fracking is permanently lost to the water cycle, the 1980s, supposedly secure for at least 10,000 as it either remains in the well, is “recycled” (used in years, migrated into a well within 80 feet of the the fracking of new wells), or is disposed of in deep surface over the course of two decades.20 Investi- injection wells, where it is unavailable to recharge gators believe that excessive pressure within the aquifers. injection well caused the rock to fracture, allowing Already, demand for water by oil and gas companies chemicals to escape. has harmed farmers and local communities: Despite the risk presented to drinking water supplies • In Texas, water withdrawals by drilling compa- by fracking, the oil and gas industry is seeking to drill nies caused drinking water wells in the town of near sources of drinking water for millions of people, Barnhart to dry up. Companies drilling in the including George Washington National Forest in Vir- Permian Basin have drilled wells and purchased ginia, White River National Forest in Colorado, Otero well water drawn from the Edwards-Trinity-Plateau Mesa in New Mexico, Wayne National Forest in Ohio, Aquifer, drying up water supplies for residential and the Delaware River Basin. and agricultural use.23 Consuming Scarce Water • Wells that provided water to farms near Carlsbad, New Mexico, have gone dry due to demand for Resources water for drilling and years of low rainfall.24 Each well that is fracked requires hundreds of thou- sands of gallons of water depending on the shale Competition for limited water resources from frack- formation and the depth and length of the horizontal ing can increase water prices for farmers and com- portion of the well. Unlike most industrial uses of wa- munities—especially in arid western states. A 2012 ter which return water to the water cycle for further auction of unallocated water conducted by the Fracking Poses Grave Threats to the Environment and Public Health 11 Northern Water Conservation District in Colorado Endangering Public Health saw gas industry firms submit high bids, with the with Air Pollution average price of water sold in the auction increas- ing from $22 per acre-foot in 2010 to $28 per Air pollution from fracking threatens the health of acre-foot in the first part of 2012.25 For the 25,000 people living and working close to the wellhead, as acre-feet of water auctioned, this would amount to well as those far away. Children, the elderly and those an added cost of $700,000. with respiratory diseases are especially at risk. Moreover, water pumped from rivers for fracking Fracking produces air pollution from the well bore as reduces the quality of the water remaining in the the well is drilled and gas is vented or flared. Emis- river because pollution becomes more concen- sions from trucks carrying water and materials to well trated. A 2011 U.S. Army Corps of Engineers study sites, as well as from compressor stations and other of the Monongahela River basin of Pennsylvania fossil fuel-fired machinery, also contribute to air pol- and West Virginia, where oil and gas companies lution. Well operations, storage of gas liquids, and withdraw water from the river for fracking, con- other activities related to fracking add to the pollu- cluded that, “The quantity of water withdrawn from tion toll. streams is largely unregulated and is beginning to show negative consequences.”26 The Corps report Making Local Residents Sick noted that water is increasingly being diverted People who live close to fracking sites are exposed to from the relatively clean streams that flow into a variety of air pollutants including volatile organic Corps-maintained reservoirs, limiting the ability of compounds (VOCs) such as benzene, xylene and the Corps to release clean water to help dilute pol- toluene. These chemicals can cause a wide range of lution during low-flow periods.27 It described the health problems—from eye irritation and headaches water supply in the Monongahela basin as “fully to asthma and cancer.31 tapped.”28 Existing data demonstrate that fracking operations Excessive water withdrawals undermine the ability are releasing these pollutants into the air at levels of rivers and streams to support wildlife. In Penn- that threaten our health. In Texas, monitoring by the sylvania, water has been illegally withdrawn for Texas Department of Environmental Quality de- fracking numerous times, to the extent of streams tected levels of benzene—a known cancer-causing being sucked dry. Two streams in southwestern chemical—in the air that were high enough to cause Pennsylvania—Sugarcamp Run and Cross Creek— immediate human health concern at two sites in the were reportedly drained for water withdrawals for Barnett Shale region, and at levels that pose long- fracking, triggering fish kills.29 term health concern at an additional 19 sites. Several chemicals were also found at levels that can cause Nationally, nearly half of all fracking wells are lo- foul odors.32 Air monitoring in Arkansas has also cated in regions with very limited water supplies. A found elevated levels of volatile organic compounds study by Ceres, a coalition of business and envi- (VOCs)—some of which are also hazardous air pollut- ronmental interests, found that nearly 47 percent ants—at the perimeter of hydraulic fracturing sites.33 of wells fracked from January 2011 through Sep- Local air pollution problems have also cropped up in tember 2012 were located in areas with “high or Pennsylvania. Testing conducted by the Pennsylvania extremely high water stress.”30 Department of Environmental Protection detected components of gas in the air near Marcellus Shale drilling operations.34 12 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Residents living near fracking sites have long suffered recommended limits. Nearly one out of 10 (9%) of the from a range of acute and chronic health problems, samples exceeded the legal limit for silica by a fac- including headaches, eye irritation, respiratory tor of 10, exceeding the threshold at which half-face problems and nausea.35 An investigation by the respirators can effectively protect workers.40 journalism website ProPublica uncovered numerous Over the past few years, health clinics in fracking reports of illness in western states from air pollution areas of Pennsylvania have reported seeing a number from fracking.36 In Pennsylvania, a homeowner in of patients experiencing illnesses associated with the town of Carmichaels described how she and her exposure to toxic substances from fracking, all of children began to suffer from a variety of symptoms whom have used false names and paid in cash. David after a compressor station was built 780 feet from Brown, a toxicologist with the Southwest Pennsylva- her house.37 Pam Judy explained to the nearby Mur- nia Environmental Health Project believes that these rysville Council that “Shortly after operations began, are mostly fracking workers, who are afraid that any we started to experience extreme headaches, runny record of their work making them sick will cost them noses, sore/scratchy throats, muscle aches and a con- their jobs.41 stant feeling of fatigue. Both of our children are expe- riencing nose bleeds and I’ve had dizziness, vomiting and vertigo to the point that I couldn’t stand and was Regional Air Pollution Threats taken to an emergency room.” Eventually, she con- Fracking also produces a variety of pollutants that vinced state officials to test air quality near her home. contribute to regional air pollution problems. VOCs That testing revealed benzene, styrene, toluene, and nitrogen oxides (NOx) in gas formations contrib- xylene, hexane, heptane, acetone, acrolein, carbon ute to the formation of ozone “smog,” which reduces tetrachloride and chloromethane in the air.38 lung function among healthy people, triggers asthma attacks, and has been linked to increases in school All indications are that these known stories just absences, hospital visits and premature death.42 scratch the surface of health damage from fracking. In cases where families made sick from fracking have Fracking is a significant source of air pollution in areas sought to hold drilling companies accountable in experiencing large amounts of drilling. A 2009 study court, the companies have regularly insisted on gag in five Dallas-Fort Worth-area counties experiencing orders as conditions of legal settlements—in a recent heavy Barnett Shale drilling activity found that oil and case even the children were barred from talking gas production was a larger source of smog-forming about fracking, for life.39 emissions than cars and trucks.43 In Arkansas, gas pro- duction in the Fayetteville Shale region was estimated Workers at drilling sites also suffer from health im- 44 to be responsible for 5,000 tons of NOx. In Wyoming, pacts. A recent investigation by the National Institute pollution from fracking contributed to such poor air for Occupational Safety and Health (NIOSH) found quality that, for the first time, the state failed to meet that workers at some fracking sites may be at risk of federal air quality standards.45 An analysis conducted lung disease as a result of inhaling silica dust from for New York State’s revised draft environmental sand injected into wells. The NIOSH investigation re- impact statement on Marcellus Shale drilling posited viewed 116 air samples at 11 fracking sites in Arkan- that, in a worst case scenario of widespread drilling sas, Colorado, North Dakota, Pennsylvania and Texas. and lax emission controls, shale gas production could Nearly half (47 percent) of the samples had levels add 3.7 percent to state NOx emissions and 1.3 per- of silica that exceeded the Occupational Safety and cent to statewide VOC emissions compared with 2002 Health Administration’s (OSHA) legal limit for work- emissions levels.46 place exposure, while 78 percent exceeded OSHA’s Fracking Poses Grave Threats to the Environment and Public Health 13 Exacerbating Global Warming gas may have a greater global warming impact than electricity from coal, especially when evaluated on a Global warming is a profound threat to virtually short timeline. An analysis by Professor Robert How- every aspect of nature and human civilization—dis- arth at Cornell and others found that, on a 20-year rupting the functioning of ecosystems, increasing timescale, electricity from natural gas is more pollut- the frequency and violence of extreme weather, and ing than electricity from coal.52 ultimately jeopardizing health, food production, and water resources for Americans and people across the Regardless of the fugitive emissions level from planet. Gas extraction produces enormous volumes fracked gas, increased production of and reliance on of global warming pollution. gas is not a sound approach to reducing our global warming emissions. Investments in gas production Fracking’s primary impact on the climate is through and distribution infrastructure divert financing and the release of methane, which is a far more potent efforts away from truly clean energy sources such as contributor to global warming than carbon dioxide. energy efficiency and wind and solar power. Gas is Over a 100-year timeframe, a pound of methane has not a “bridge fuel” that prepares us for a clean energy 25 times the heat-trapping effect of a pound of car- future; rather, increasing our use of gas shifts our reli- bon dioxide.47 Methane is even more potent relative ance from one polluting fuel to another. to carbon dioxide at shorter timescales, at least 72 times more over a 20-year period. Additionally, to the extent that fracking produces oil instead of gas, fracking does nothing to reduce Intentional venting and leaks during the extraction, global warming pollution: in fact, refining oil into transmission and distribution of gas release substan- useable products like gasoline and diesel, and then tial amounts of methane to the atmosphere. The U.S. burning those products, is a huge source of global Environmental Protection Agency revised downward warming pollution. its estimate of fugitive methane emissions from fracking in April 2013, citing improved practices by the industry.48 A study conducted with industry Damaging America’s Natural cooperation and released in September 2013 found Heritage very low fugitive emissions of methane at the wells Fracking transforms rural and natural areas into in- included in the study, though the findings may not dustrial zones. This development threatens national be representative of standard industry practice.49 parks and national forests, damages the integrity of However, recent air monitoring by researchers at the landscapes and habitats, and contributes to water National Oceanic and Atmospheric Administration pollution problems that threaten aquatic ecosys- and the University of Colorado, Boulder, near a gas tems. and oil field in Colorado revealed fugitive methane Before drilling can begin, land must be cleared of emissions equal to 2.3 to 7.7 percent of the gas ex- vegetation and leveled to accommodate drilling tracted in the basin, not counting the further losses equipment, gas collection and processing equip- that occur in transportation.50 Recent aerial sam- ment, and vehicles. Additional land must be cleared pling of emissions over an oil and gas field in Uintah for roads to the well site, as well as for any pipelines County, Utah, revealed methane emissions equal to and compressor stations needed to deliver gas to 6.2 to 11.7 percent of gas production.51 market. A study by the Nature Conservancy of frack- The global warming impact of fracked natural gas ing infrastructure in Pennsylvania found that well is so great that electricity produced from natural pads average 3.1 acres and related infrastructure 14 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level damages an additional 5.7 acres.53 Often, this de- The forest also hosts 4,000 miles of streams that velopment occurs on remote and previously undis- provide water to several local communities and turbed wild lands. feed into the Colorado River. As oil and gas companies expand fracking activities, • Delaware River Basin – This basin, which spans national parks, national forests and other iconic land- New Jersey, New York, Pennsylvania and Delaware, scapes are increasingly at risk. Places the industry is is home to three national parks and provides seeking to open for fracking include: drinking water to 15 million people.55 • White River National Forest – Located in Colora- • Wayne National Forest – Part of Ohio’s beauti- do, this forest draws 9.2 million visitors per year ful Hocking Hills region, most of the acres in the for hiking, camping and other recreation, making forest are to be leased for drilling near the sole 56 it the most visited national forest in the country.54 drinking water source for 70,000 people. Photo: Peter Aengst via SkyTruth/EcoFlight. Wells and roads built to support fracking in Wyoming’s Jonah gas field have caused extensive habitat fragmentation. Fracking Poses Grave Threats to the Environment and Public Health 15 • George Washington National Forest – This area of Drexel University found an association between in- hosts streams in Virginia and West Virginia that creased density of gas drilling activity and degradation feed the James and Potomac Rivers, which provide of ecologically important headwater streams.63 the drinking water for millions of people in the Water contamination related to fracking has caused Washington, D.C., metro area. several fish kills in Pennsylvania. In 2009, a pipe con- • Otero Mesa – A vital part of New Mexico’s natural taining freshwater and flowback water ruptured in heritage, Otero Mesa is home to pronghorn Washington County, Pennsylvania, triggering a fish antelope and a freshwater aquifer that could be kill in a tributary of Brush Run, which is part of a a major source of drinking water in this parched high-quality watershed.64 That same year, in the same southwestern state.57 county, another pipe ruptured at a well drilled in a public park, killing fish and other aquatic life along a The disruption and fragmentation of natural habitat three-quarter-mile length of a local stream.65 can put wildlife at risk. In Wyoming, for example, extensive gas development in the Pinedale Mesa region has coincided with a significant reduction in Imposing Costs on Communities the region’s population of mule deer. A 2006 study As with prior extractive booms, the fracking oil and gas found that the construction of well pads drove away rush disrupts local communities and imposes a wide female mule deer.58 The mule deer population in the range of immediate and long term costs on them. area dropped by 50 percent between 2001 and 2011, as fracking in the area continued and accelerated.59 Ruining Roads, Straining Services Concerns have also been raised about the impact of As a result of its heavy use of publicly available infra- gas development on pronghorn antelope. A study by structure and services, fracking imposes both immedi- the Wildlife Conservation Society documented an 82 ate and long-term costs on taxpayers. percent reduction in high-quality pronghorn habitat The trucks required to deliver water to a single frack- in Wyoming’s gas fields, which have historically been ing well cause as much damage to roads as 3.5 million 60 key wintering grounds. car journeys, putting massive stress on roadways and Birds may also be vulnerable, especially those that bridges not constructed to handle such volumes of depend on grassland habitat. Species such as the heavy traffic. Pennsylvania estimates that repairing northern harrier, short-eared owl, bobolink, upland roads affected by Marcellus Shale drilling would cost 66 sandpiper, loggerhead shrike, snowy owl, rough- $265 million. legged hawk and American kestrel rely on grassland Fracking also strains public services. Increased heavy 61 habitat for breeding or wintering habitat. These vehicle traffic has contributed to an increase in traf- birds typically require 30 to 100 acres of undisturbed fic accidents in drilling regions. At the same time, the 62 grassland for habitat. Roads, pipelines and well influx of temporary workers that typically accompanies pads for fracking may fragment grassland into seg- fracking puts pressure on housing supplies, thereby ments too small to provide adequate habitat. causing social dislocation. Governments respond by The clearing of land for well pads, roads and pipe- increasing their spending on social services and subsi- lines may threaten aquatic ecosystems by increasing dized housing, squeezing tax-funded budgets. sedimentation of nearby waterways and decreasing Governments may even be forced to spend tax money shade. A study by the Academy of Natural Sciences to clean up orphaned wells—wells that were never 16 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level properly closed and whose owners, in many cases, no The cost of cleaning up environmental damage from longer exist as functioning business entities. Though the current oil and gas boom may fall to taxpayers, oil and gas companies face a legal responsibility to as has happened with past booms. For example, as plug wells and reclaim drilling sites, they have a track of 2006, more than 59,000 orphan oil and gas wells record of leaving the public holding the bag.67 were on state waiting lists for plugging and remedia- tion across the United States, with at least an ad- Risks to Local Businesses, Homeowners ditional 90,000 wells whose status was unknown or and Taxpayers undocumented.72 Texas alone has more than 7,800 orphaned oil and gas wells.73 These wells pose a con- Fracking imposes damage on the environment, pub- tinual threat of groundwater pollution and have cost lic health and public infrastructure, with significant the state of Texas more than $247 million to plug.74 economic costs, especially in the long run after the The current fracking boom ultimately may add to this initial rush of drilling activity has ended. A 2008 study catalog of orphaned wells. by the firm Headwaters Economics found that West- ern counties that have relied on fossil-fuel extraction for growth are doing worse economically than their Threatening Public Safety peers, with less-diversified economies, a less-educat- Fracking harms public safety by increasing traffic in ed workforce, and greater disparities in income.68 rural areas where roads are not designed for such high volumes, by creating an explosion risk from Other negative impacts on local economies include methane, and by increasing earthquake activity. downward pressure on home values and harm to farms. Pollution, stigma and uncertainty about the Increasing traffic—especially heavy truck traffic—has future implications of fracking can depress the prices contributed to an increase in traffic accidents and fa- of nearby properties. One Texas study found that talities in some areas in which fracking has unleashed homes valued at more than $250,000 and located a drilling boom, as well as an increase in demands for within 1,000 feet of a well site lost 3 to 14 percent of emergency response. In the Bakken Shale oil region their value.69 Fracking also has the potential to affect of North Dakota for example, the number of high- agriculture, both directly through damage to live- way crashes increased by 68 percent between 2006 stock from exposure to fracking fluids, and indirectly and 2010, with the share of crashes involving heavy through economic changes that undermine local trucks also increasing over that period.75 A 2011 agricultural economies. survey by StateImpact Pennsylvania in eight counties found that 911 calls had increased in seven of them, Fracking can increase the need for public invest- with the number of calls increasing in one county by ment in infrastructure and environmental cleanup. 49 percent over three years, largely due to an in- Fracking-related water demand may also lead to calls crease in incidents involving heavy trucks.76 for increased public spending on water infrastruc- ture. Texas, for example, adopted a State Water Plan Methane contamination of well water poses a risk of in 2012 that calls for $53 billion in investments in the explosion if the gas builds up inside homes. In both state water system, including $400 million to address Ohio and Pennsylvania, homes have exploded after unmet needs in the mining sector (which includes high concentrations of methane inside the buildings hydraulic fracturing) by 2060.70 Fracking is projected were ignited by a spark.77 to account for 42 percent of water use in the Texas mining sector by 2020.71 Fracking Poses Grave Threats to the Environment and Public Health 17 Another public safety hazard stems from earth- quakes triggered by injection wells. For example, on New Year’s Eve in 2011—shortly after Ohio began accepting increasing amounts of wastewater from Pennsylvania—a 4.0 earthquake shook Youngstown, Ohio. Seismic experts at Columbia University de- termined that pumping fracking wastewater into a nearby injection well caused the earthquake.78 Earthquakes triggered by injection well wastewater disposal have happened in Oklahoma, Arkansas, Texas, Ohio and Colorado. The largest quake—a mag- nitude 5.7 temblor in Oklahoma that happened in 2011—injured two people, destroyed 14 homes and buckled highways. People felt the quake as far as 800 miles away.79 As fracking wastewater volumes have increased dramatically since 2007, the number of earthquakes in the central United States, where injection well dis- posal is common, has increased by more than 1,100 percent compared to earlier decades.80 Scientists at the U.S. Geological Survey have concluded that humans are likely the cause.81 After reviewing data on the Oklahoma quake, Dr. Geoffrey Abers, a seis- mologist at the Lamont-Doherty Earth Observatory, concluded that, “the risk of humans inducing large earthquakes from even small injection activities is probably higher” than previously thought.82 18 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Quantifying the State and National Impacts of Fracking racking imposes numerous costly impacts in data make it difficult to isolate high-volume on our environment and public health. This fracking from other practices. To address this report seeks to estimate several key impacts of challenge, we collected data on unconventional frackingF for oil and gas, with a primary focus on high- drilling targets (shale gas, shale oil, and tight-gas volume fracking. sands) and practices (horizontal and directional drilling) to ensure the comprehensiveness of the There have been few, if any, efforts to quantify the data. Where possible, we then narrowed the data cumulative impacts of fracking at a state or national to include only those wells using high-volume scale. The task is made difficult, in part, by differing hydraulic fracturing involving more than 100,000 definitions and data collection practices for uncon- gallons of water. ventional drilling used in the states. These variations Photo: The Downstream Project via SkyTruth/LightHawk. More than 6,000 shale gas/liquids wells, such as this well site in Tioga County, have been drilled in Pennsylvania since 2005. Quantifying the State and National Impacts of Fracking 19 The data presented in the following sections come Wells Fracked by State from multiple sources, including state databases, The most basic measure of fracking’s scope is a tally estimates from knowledgeable state employees, and of how many fracking wells have been drilled. In information provided by oil and gas companies to a addition, having an accurate count of wells by state national website. As a result, the quality of the data offers a basis for estimating specific impacts to water, varies and figures may not be directly comparable air and land. from state to state. Nonetheless, the numbers paint an initial picture of the extensive environmental and Fracking has occurred in at least 17 states (see Table public health damage from fracking. 1), affecting approximately 82,000 wells. In the eastern U.S., Pennsylvania reports the most fracking wells since 2005, with 6,651 wells tapping into the Marcellus and Utica shales. More than 5,000 fracking Table 1. Estimate of Fracking Wells83 wells have been drilled in North Dakota to produce Fracking oil from the Bakken formation. Western states with Wells since Fracking Wells the most fracking include Colorado, New Mexico and Utah. State 2005 Drilled in 2012 Arkansas 4,910 719 Absent policies to rein in fracking, fracking is likely Colorado 18,168 1,896 to expand in these and other states. Tennessee cur- Kansas 407 236 rently has a handful of wells but more will soon be fracked in the Cumberland Forest.84 One test well was Louisiana 2,327 139 fracked in Georgia in the past year.85 Illinois recently Mississippi 9 Unavailable adopted new regulations governing fracking, paving Montana 264 174 the way for the practice there.86 Oil and gas compa- New Mexico 1,353 482 nies are seeking to expand to states such as Califor- North Dakota 5,166 1,713 nia, New York, Maryland and North Carolina where there has been no such activity to date. In New York, Ohio 334 234 as many as 60,000 wells could be drilled.87 Oklahoma 2,694 Unavailable Pennsylvania 6,651 1,349 Wastewater Produced Tennessee 30 Unavailable One of the more serious threats fracking poses to Texas 33,753 13,540 drinking water is the millions of gallons of toxic Utah 1,336 765 wastewater it generates. Virginia 95 1 While there are many ways in which fracking can West Virginia* 3,275 610 contaminate drinking water—including but not lim- Wyoming 1,126 468 ited to spills of fracking fluid, well blowouts, leaks of TOTAL 81,898 22,326 methane and other contaminants from the well bore “Unavailable” means information was not available to determine into groundwater, and the possible eventual migra- when wells were drilled. See methodology for complete details. tion of fluids from shale to the water table—one of the most serious threats comes from the millions of * Data for West Virginia is for permitted fracking wells, not wells that have been drilled. Data were not available on drilled wells. gallons of toxic wastewater fracking generates. 20 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Table 2 shows how much wastewater has been pro- duced from fracking wells in selected states. In some states, such as New Mexico, North Dakota, Ohio, Penn- sylvania and Utah, well operators submit regular reports on the volume of wastewater, oil and gas produced from their wells. In some states where operators do not report wastewater volumes, we estimated wastewater volumes using state-specific data as described in the methodology. These estimates are for wastewater only, and do not include other toxic wastes from fracking, such as drilling muds and drill cuttings. The rapid growth of fracking has caused wastewater volumes to increase rapidly. In the Marcellus Shale underlying Pennsylvania, West Virginia and Ohio, for example, wastewater production increased six-fold from 2004 to 2011.89 Table 2. Wastewater from Fracking in 201288 Wastewater Produced State (million gallons) Arkansas 800 Colorado 2,200 Fracking wastewater is disposed Kansas No estimate into Class II injection wells in Louisiana No estimate Ohio. “Receiving” wells currently Mississippi* 10 accept fracking wastewater. “Non- Montana 360 receiving” wells are those wells that New Mexico 3,000 could receive fracking wastewater North Dakota** 12,000 but haven’t to date. Data mapped by Ohio 30 the FracTracker Alliance on Frac- Oklahoma No estimate Tracker.org. Original data source: Pennsylvania 1,200 Bulk Transporter Magazine, accessed Tennessee No estimate at www.fractracker.org/2013/06/oh- Texas 260,000 waste-network, 23 July 2013. Utah 800 Virginia No estimate In 2012 alone, fracking in Pennsylvania produced West Virginia No estimate 1.2 billion gallons of wastewater, almost as much Wyoming No estimate as was produced in a three-year period from 2009 TOTAL 280,000 to 2011.90 * Data for Mississippi are for 2012-2013. ** Data for North Dakota are cumulative to early 2013. Quantifying the State and National Impacts of Fracking 21 This huge volume of polluted wastewater creates Chemicals Used many opportunities for contaminating drinking Fracking fluid consists of water mixed with chemicals water. More wells and more wastewater increase that is pumped underground to frack wells. Though the odds that the failure of a well casing or gasket, in percentage terms, chemicals are a small compo- a wastewater pit or a disposal well will occur and nent of fracking fluid, the total volume of chemicals that drinking water supplies will be contaminated. used is immense. Moreover, as the sheer volume of wastewater generated exceeds local disposal capacity, drilling The oil and gas industry estimates that 99.2 percent operators are increasingly looking to neighbor- of fracking fluid is water (by volume) and the other ing states as convenient dumping grounds. For 0.8 percent is a mix of chemicals.94 Assuming that example, in 2011, more than 100 million gallons of this percentage is correct and has held true since Pennsylvania’s fracking waste were trucked to Ohio 2005, that means oil and gas companies have used 2 for disposal into underground injection wells.91 (See billion gallons of chemicals. map of Ohio disposal wells.) These chemicals routinely include toxic substances. As the volume of this toxic waste grows, so too will According to a 2011 congressional report, the toxic the likelihood of illegal dumping. For example, in chemicals used in fracking include methanol, glutar- 2013 Ohio authorities discovered that one drilling aldehyde, ethylene glycol, diesel, naphthalene, xy- waste operator had dumped thousands of gallons lene, hydrochloric acid, toluene and ethylbenzene.95 of fracking wastewater into the Mahoning River.92 More recently, an independent analysis of data sub- And in Pennsylvania, prosecutors recently charged mitted by fracking operators to FracFocus revealed a different company with dumping fracking that one-third of all frack jobs reported there use at waste.93 least one cancer-causing chemical.96 These toxic sub- stances can enter drinking water supplies from the For other industries, the threats posed by toxic well, well pad or in the wastewater disposal process. waste have been at least reduced due to the adop- tion of the federal Resource Conservation Recovery Act (RCRA), which provides a national framework Water Used for regulating hazardous waste. Illegal dumping is Since 2005, fracking has used at least 250 billion gal- reduced by cradle-to-grave tracking and criminal lons of water across the nation. Extrapolating from penalties. Health-threatening practices such as industry-reported figures on water use at more than open waste pits, disposal in ordinary landfills, and 36,000 wells since 2011, we estimated total water road spreading are prohibited. However, waste use for all wells that were fracked from 2005 through from oil and gas fracking is exempt from the haz- mid-2013. (See Table 3.) ardous waste provisions of RCRA—exacerbating the toxic threats posed by fracking wastewater. The greatest total water consumption occurred in Texas, at the same time the state was struggling with extreme drought. Other states with high water use include Pennsylvania, Arkansas and Colorado. The amount of water used for fracking in Colorado was enough to meet the water needs of nearly 200,000 Denver households for a year.97 22 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Table 3. Water Used for Fracking98 Air Pollution Created Total Water Used since 2005 Fracking created hundreds of thousands of tons of air pollu- State (million gallons) tion in 2012. As shown in Table 4, well-site operations during Arkansas 26,000 drilling and well completion generated approximately Colorado 26,000 450,000 tons of health-threatening air pollution. And that Kansas 670 does not even include the significant emissions from ongo- Louisiana 12,000 ing operations, compressors, waste pits and truck traffic to Mississippi 64 and from drilling sites carrying supplies and personnel. Montana 450 This air pollution estimate for all wells is based on emis- New Mexico 1,300 sions figures from wells in the Marcellus Shale. Different North Dakota 12,000 drilling targets and practices may lead to different results.99 Ohio 1,400 Additional research and improved data availability will Oklahoma 10,000 help clarify the amount of pollution occurring in different Pennsylvania 30,000 regions. Tennessee 130 The 2012 NO emissions from the early stages of fracking in Texas 110,000 x Colorado were equal to 27 percent of the NOx produced by Utah 590 power plants in the state, assuming fracking well emissions Virginia 15 rates were similar to those in the Marcellus.100 In Pennsyl- West Virginia 17,000 vania, fracking produced NOx equal to 7 percent of that Wyoming 1,200 emitted in 2011 by electricity generation, a major source of TOTAL 250,000 smog-forming emissions. Table 4. Estimated Air Pollution Produced from Early Stages of Fracking (Drilling and Well Completion) in 2012 (tons) State Particulate Matter NOx Carbon Monoxide VOCs Sulphur Dioxide Arkansas 400 5,300 8,100 700 20 Colorado 1,100 14,000 21,000 2,000 50 Kansas 100 1,700 2,700 200 6 Louisiana 80 1,000 1,600 100 3 Mississippi Unavailable Unavailable Unavailable Unavailable Unavailable Montana 100 1,300 2,000 200 4 New Mexico 300 3,600 5,400 500 10 North Dakota 1,000 13,000 19,000 2,000 40 Ohio 100 1,700 2,600 200 6 Oklahoma Unavailable Unavailable Unavailable Unavailable Unavailable Pennsylvania 800 10,000 15,000 1,000 30 Tennessee Unavailable Unavailable Unavailable Unavailable Unavailable Texas 7,800 100,000 153,000 14,000 300 Utah 400 5,700 9,000 1,000 20 Virginia 1 7 11 1 0 West Virginia 400 4,500 6,900 600 20 Wyoming 270 3,500 5,300 500 12 TOTAL 13,000 170,000 250,000 23,000 600 Quantifying the State and National Impacts of Fracking 23 Global Warming Pollution Table 5. Global Warming Pollution from Released Completion of Fracking Wells Completion of fracking wells produced global warm- Based on Well Completion from ing pollution of 100 million metric tons of carbon 2005 to 2012 (metric tons of dioxide equivalent from 2005 to 2012, equal to emis- State carbon dioxide-equivalent) sions from 28 coal-fired power plants in a year.101 Arkansas 6,200,000 Using the data on the number of fracking wells, we Colorado 23,000,000 estimated emissions from well completion using an Kansas 500,000 emissions rate from a recent study by researchers Louisiana 2,900,000 at MIT. The researchers calculated that the average fracked shale gas well completed in 2010 released Mississippi 11,000 110,000 pounds of methane during the first nine Montana 300,000 days of operation.102 The researchers assumed that New Mexico 1,700,000 70 percent of wells were operated with equipment North Dakota 6,500,000 to limit emissions, that 15 percent of wells flared gas, Ohio 420,000 and that 15 percent of wells vented gas. Their calcu- lations did not include methane emissions after the Oklahoma 3,400,000 first nine days, such as during processing, transmis- Pennsylvania 8,300,000 sion and distribution, nor did they include carbon di- Tennessee No estimate oxide emissions from trucks and drilling equipment. Texas 40,000,000 We used data on the number of wells fracked since Utah 1,700,000 2005 (as presented in Table 1 in “Estimate of Frack- ing Wells ”) to estimate methane emissions. Table 5 Virginia 120,000 presents estimated emissions from completion of West Virginia 4,100,000 fracking wells from 2005 to 2012. Wyoming 1,400,000 In Texas, emissions from completion of fracking wells TOTAL 100,000,000 since 2005 are equal to those produced by 12 coal- fired power plants in a year.103 Completion of wells in Pennsylvania produced emissions equal to the pollu- same emissions. In reality, some wells produce gas, tion from 1.7 million passenger vehicles in a year.104 some produce oil, and some wells produce gas that requires additional processing.105 Finally, even those This estimate of emissions from well completion states that track the number of fracking wells typi- is both incomplete and includes several points of cally don’t track well type. uncertainty. First and foremost, it does not include emissions from ongoing operation of wells. Sec- We believe this estimate of emissions from well ond, in states where regulators do not have a firm completions understates total emissions from frack- estimate of the number of fracking wells, such as in ing wells. To compare this estimate of emissions Colorado and Texas, our conservative estimate of the from well completion to an estimate from ongoing number of fracking wells results in an underestimate emissions and to avoid the problem of uncertainty of emissions. Introducing uncertainty, this estimate regarding emissions by well type, we estimated emis- treats all wells as if they were the same and have the sions based on gas production for a few states. 24 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Researchers at Cornell have studied emissions from Acres of Land Damaged fracking in five unconventional gas formations.106 Nationally, land directly damaged for fracking totals The researchers estimated the methane emissions 360,000 acres. (See Table 6.) This estimate includes released from multiple steps in the fracking pro- the amount of land that has been cleared for roads, cess—drilling, fracking and processing—and calcu- well sites, pipelines and related infrastructure in each lated emissions as a percentage of produced gas.107 state. However, the total amount of habitat and land- Using estimates of gas production by state, where scape affected by fracking is much greater. In trea- available, we calculated statewide global warming sured open spaces, a single well-pad can mar a vista pollution from fracking. For the two states where seen from miles around. A study of fracking develop- we have complete production data—Pennsylvania ment in Pennsylvania estimated that forest fragmen- and North Dakota—the production-based emis- tation affected more than twice as much land as was sions estimate is higher than the estimate based on directly impacted by development.109 the number of completed wells. Fracking activity in Colorado damaged 57,000 acres, Using our production-based method, Pennsylva- equal to one-third of the acreage in the state’s park nia, North Dakota and Colorado had the highest system.110 In Pennsylvania, the amount of land emissions. Pennsylvania produced the most global directly affected by fracking-related development warming pollution from fracking for gas. In 2012, since 2005 is equal to all the farmland protected the state created 24 million metric tons of carbon since 1999 through the state’s Growing Greener land dioxide-equivalent, as much pollution as produced preservation program.111 by seven coal-fired power plants or 5 million pas- 108 senger vehicles. Table 6. Land Damaged for Fracking112 State Acres Damaged since 2005 Photo: Gerry Dincher/Flickr. Arkansas 24,000 Colorado 57,000 Kansas No estimate Louisiana No estimate Mississippi No estimate Montana 230 New Mexico 8,900 North Dakota 50,000 Ohio 1,600 Oklahoma 22,000 Pennsylvania 33,000 Tennessee No estimate Texas 130,000 Utah 9,000 Virginia 460 West Virginia 16,000 Storage tanks can be a significant Wyoming 5,000 source of fugitive methane emissions. TOTAL 360,000 Quantifying the State and National Impacts of Fracking 25 Photo: ©Dennis Dimick/Flickr. A grid of drilling sites and roads, similar to those used in fracking, lies across the landscape near Odessa, Texas. In the years to come, fracking may affect a much over, as noted earlier in this report, the oil and gas bigger share of the landscape. According to a recent industry is seeking access to even more acres of land analysis by the Natural Resources Defense Council, for fracking—including areas on the doorsteps of our 70 of the nation’s largest oil and gas companies have national parks, and inside our national forests—some leases to 141 million acres of land, bigger than the of which contain sources of drinking water for mil- combined areas of California and Florida.113 More- lions of Americans. 26 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Policy Recommendations s evidenced by the data in this report, frack- • At a minimum, state officials should allow cities, ing is causing extensive damage to the en- towns and counties to protect their own citizens vironment and public health in states across through local bans and restrictions on fracking. Athe country. States as disparate as Colorado, North Dakota, Pennsylvania and Texas suffer from air pol- • Moreover, states bordering on the fracking boom lution, water pollution, habitat disruption and water should also bar the processing of fracking waste depletion caused by widespread fracking. Wherever so that they will not become dumping grounds fracking has occurred, it has left its mark on the envi- for fracking operations next door. Vermont has ronment and our well-being. already banned fracking and its waste, and similar proposals are under consideration in other states. Fracking has additional impacts not documented in this report. Environmental damage includes water Where fracking is already happening, the least we pollution from spills of fracking fluids and methane should expect from our government is to reduce the leaks into groundwater, as well as air pollution from environmental and health impacts of dirty drill- toxic emissions that causes both acute and chronic ing as much as possible, including: health problems for people living near wells. Eco- • The federal government should close the nomic and social damage includes ruined roads and loopholes that exempt fracking from key provi- damage to farm economies. sions of our federal environmental laws. For The scale of this threat is growing almost daily, with example, fracking wastewater, which often thousands of new wells being added across the contains cancer-causing and even radioactive nation each year. Given the scale and severity of material, is exempt from our nation’s hazardous fracking’s myriad impacts, constructing a regulatory waste laws. regime sufficient to protect the environment and • Federal and state governments should protect public health from dirty drilling—much less enforc- treasured open spaces and vital drinking water ing such safeguards at more than 80,000 wells, plus supplies from the risks of fracking. In 2011, the processing and waste disposal sites across the coun- Obama administration’s science advisory panel try—seems implausible at best. on fracking recommended the “[p]reservation of In states where fracking is already underway, an im- unique and/or sensitive areas as off limits to drill- 114 mediate moratorium is in order. In all other states, ing and support infrastructure.” In keeping with banning fracking is the prudent and necessary this modest directive, dirty fracking should not be course to protect the environment and public allowed near our national parks, national forests or health. in watersheds that supply drinking water. Policy Recommendations 27 • Policymakers should end worst practices. Frack- While we conclude that existing data alone is suf- ing operators should no longer be allowed to ficient to make the case against fracking, additional use open waste pits for holding wastewater. The data will provide a more complete picture and is use of toxic chemicals should not be allowed in critical for local communities and residents to as- fracking fluids. Operators should be required to sess ongoing damage and liability where fracking meet aggressive water use reduction goals and to is already occurring. As this report revealed, data recycle wastewater. available on fracking are inconsistent, incomplete and difficult to analyze. To remedy this, oil and gas To ensure that the oil and gas industry—rather than companies should be required to report all fracking taxpayers, communities or families—pays the costs wells drilled, all chemicals used, amount of water of fracking damage, states and the Bureau of Land used, and volume of wastewater produced and toxic Management should require robust financial assur- substances therein. Reporting should occur into an ance from operators at every well site. accessible, national database, with chemical use data provided 90 days before drilling begins. 28 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Methodology his report seeks to estimate the cumulative For data on water use and for teasing apart state data impacts of fracking for oil and gas in the on conventional and unconventional wells, we relied United States. We attempted to limit the heavily on the work done by SkyTruth to make data scopeT of the data included in the report to wells reported by the fracking industry more accessible. using high-volume hydraulic fracturing with hori- Oil and gas drilling companies report some of their zontal drilling, because that new technology has the fracking activities to the FracFocus website, provid- greatest environmental impacts and its use is in- ing information on individual wells in separate PDF creasing rapidly. However, the definition of and data files. SkyTruth compiles these individual PDFs and ex- collection practices for unconventional drilling vary tracts the data “as is,” placing the data into a standard significantly from state to state, making it difficult— machine-readable database that can be downloaded and in some cases impossible—to limit our study and analyzed. We downloaded SkyTruth’s Fracking only to those wells that have been developed using Chemical Database from frack.skytruth.org/fracking- high-volume fracking. chemical-database/frack-chemical-data-download on 12 June 2013. References below to SkyTruth data To ensure that our estimates included the most or API numbers from SkyTruth refer to this database. comprehensive data possible, we began by collect- ing—largely from state oil and gas regulators, as de- The data we were able to collect undercounts the scribed below—data on all unconventional drilling scope of fracking and its damage, for several reasons. targets and practices (excluding acidization). Where First, when the data were unclear, we made conser- possible, we then narrowed the data to include only vative assumptions and chose conservative method- those wells using high-volume hydraulic fracturing ologies. Second, the FracFocus data we drew upon involving more than 100,000 gallons of water and/ for some of our calculations are incomplete (see text or horizontal drilling. In many states, the information box “Problems with FracFocus Data”). needed to identify these wells was lacking. In those Our analysis does not include data from several states, we included all wells using unconventional states where fracking is a subject of policy debates, drilling practices in the data. In the section “Number including Michigan and California. In those states, of Wells, Wastewater and Produced Gas,” we explain the data show that little to no fracking has occurred what types of drilling are included in the data for using high volumes of water because oil and gas each state. companies have not yet begun to combine horizon- tal drilling with fracking. In these states, hydraulic fracturing has taken place in vertical wells, which require far less water. Methodology 29 Problems with FracFocus Data Data collected on the FracFocus website have several limitations: FracFocus does not include all fracking wells in the nation, the data that are provided can be of poor quality, and loopholes in reporting requirements enable companies to hide some information. The FracFocus website does not include data on all fracking wells. The website came into operation in 2011, after thousands of wells had already been fracked and in most cases operators have not retroactively entered information on older wells. Furthermore, in many states, reporting to FracFocus is voluntary and therefore the website does not cover all wells fracked since 2011. Only Colorado, Louisiana, Montana, New Mexico, North Dakota, Oklahoma, Pennsylvania, Texas and Utah require reporting to FracFocus.115 In most of those states, however, the reporting requirement was adopted in 2012 or later and therefore not all earlier fracking activity is included on FracFocus. Table 7. FracFocus Contains an Incomplete Count of Fracking Wells (Using More than 100,000 Gallons of Water) Count from FracFocus Count Based on State Data Fracking Wells Fracking Wells Fracking Wells Fracking Wells State since 2005 in 2012 since 2005 in 2012 Arkansas 1,461 611 4,910 719 Colorado 4,996 2,308 18,168 1,896 Kansas 150 108 407 236 Louisiana 1,078 346 2,327 139 Mississippi 5 3 9 Unavailable Montana 264 174 264 174 New Mexico 916 515 1,353 482 North Dakota 2,654 1,653 5,166 1,713 Ohio 156 121 334 234 Oklahoma 2,097 1,270 2,694 Unavailable Pennsylvania 2,668 1,295 6,651 1,349 Tennessee 2 0 30 Unavailable Texas 16,916 9,893 33,753 13,540 Utah 1,336 765 1,336 765 Virginia 5 3 95 1 West Virginia 280 170 3,275 610 Wyoming 1,126 468 1,126 468 TOTAL 36,457 19,923 81,898 22,326 We compared the data we collected from states with the data included in FracFocus. SkyTruth’s database of FracFocus data contains records for approximately 36,000 unique wells that used more than 100,000 gallons of water. Based on data we collected directly from states, we tallied more than 80,000 wells from the beginning of 2005 through mid-2013. Table 7 shows the state-by-state differences between our figures and those derived from FracFocus. 30 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Further evidence of how much data are missing from FracFocus comes from a comparison of water use in all Texas wells reported to FracFocus by individual oil and gas companies versus water use calculated for the Texas Oil & Gas Association. This comparison shows that the figures in FracFocus in 2011 might be 50 percent too low. According to Jean-Philippe Nicot, et al., for the Texas Oil & Gas Association, Oil & Gas Water Use in Texas: Update to the 2011 Mining Water Use Report, September 2012, fracking used 81,500 acre-feet of water in Texas in 2011 and consumed 68,400 acre-feet. In contrast, the data from SkyTruth’s compilation of FracFocus data suggest total use was 46,500 acre-feet in 2011. Reporting by Texas operators was voluntary at this point, and in 2011 only half of Texas wells were reported to FracFocus, according to Leslie Savage, Chief Geologist, Oil and Gas Division of the Texas Railroad Commission, personal communication, 20 June 2013. Second, the quality and scope of the data are inconsistent. Typographical errors and incorrect chemical identifying numbers mean some of the data are unusable. Finally, companies are not required to report all the chemicals they use in the fracking process. Through a trade-secrets exemption, drilling companies can mask the identities of chemicals. In some states, up to 32 percent of the chemicals used are not disclosed because companies claim they are trade secrets, per SkyTruth, SkyTruth Releases Fracking Chemical Database, 14 November 2012. Number of Wells, Wastewater Our calculation of the volume of flowback and pro- duced water in Arkansas is based on a finding in J.A. and Produced Gas Veil, Environmental Science Division, Argonne National We obtained most of our data on a state by state Laboratory, for the U.S. Department of Energy, Office basis for the number of wells, the amount of waste- of Fossil Energy, National Energy Technology Labora- water produced, and the amount of gas produced. tory, Water Management Practices Used by Fayetteville Shale Gas Producers, June 2011. Veil reports that one Arkansas producer in the Fayetteville Shale estimates that Data on well completions in Arkansas came from “the combined return volume of flowback water and Arkansas Oil and Gas Commission, Fayetteville Well subsequent produced water for the Fayetteville shale Completion Report, downloaded from www.aogc2. is … about 25%.” We multiplied this by data on water state.ar.us/FayettevilleShaleInfo/regularly%20up- consumed to frack Fayetteville shale wells in 2012. dated%20docs/B-43%20Field%20-%20Well%20 Completions.pdf, 4 June 2013. Essentially all these Colorado wells are fracked, per James Vinson, Webmaster, Little Colorado does not track fracking wells separately Rock Office, Arkansas Oil & Gas Commission, personal from other oil and gas wells. To estimate the number communication, 4 June 2013. We included wells with of fracking wells in the state, we counted the number no date listed for “Date of 1st Prod” when they had of wells in Weld, Boulder, Garfield and Mesa counties other remarks indicating they were drilled in the past with spud dates of 2005 or later. Data on well comple- few years. tions came from Colorado Oil and Gas Conservation Methodology 31 Commission, 2013 Production Summary, accessed at Mississippi cogcc.state.co.us/, 3 September 2013, and guidance Mississippi began requiring permits for fracking wells on which counties to include came from Diana Burn, only in March 2013. Therefore, we used data provid- Eastern Colorado Engineering Supervisor, Colorado ed to FracFocus by oil and gas companies involved Oil and Gas Commission, personal communication, in fracking. We used the “Find a Well” function on the 4 September 2013. Many wells in Weld and Boulder FracFocus website to search for wells in Mississippi as counties use fracking to tap the Niobrara and Codell of 18 June 2013. Reporting to the FracFocus website formations, while wells in Garfield and Mesa counties is voluntary for companies in Mississippi, so the target the Piceance Basin. We excluded wells from all website likely undercounts fracking wells in the state. other counties because those wells use lower vol- umes of water due to shallower wells, foam fracking, Monthly data on produced water are available well or recompletion of existing wells. by well from the Mississippi Oil and Gas Board’s website (http://gis.ogb.state.ms.us/MSOGBOnline/) Our estimate of gas production and produced water using individual API numbers. We looked up three volumes came from Colorado Oil and Gas Conserva- wells, one of which has been abandoned, and used tion Commission, 2012 Annual Production Summary the volume of produced water to calculate a state (Access database), downloaded 25 June 2013. We average. selected for gas and water production data from all wells drilled in Weld, Garfield, Boulder and Mesa counties since 2005 as described above. Montana Our count of fracking wells came from the FracFocus Kansas database. We screened for wells that reported using more than 100,000 gallons of water, and counted 264 We obtained data on all horizontal wells from Kan- wells. sas Geological Survey, Oil and Gas Well Database, accessed at chasm.kgs.ku.edu, 30 May 2013. We This estimate is conservative. A tally of new horizon- counted only those wells with a listed spud date. We tal and recompleted horizontal wells in Montana were unable to obtain an estimate of wastewater Board of Oil and Gas Conservation, Horizontal Well produced. Completion Count, accessed at www.bogc.dnrc. mt.gov, 29 May 2013 turned up 1,052 wells, which Louisiana may include some coalbed methane wells. We obtained data on shale wells drilled in the To obtain an estimate of produced water, we down- Haynesville formation from Louisiana Department loaded the list of API numbers in Montana reported of Natural Resources, Haynesville Shale Wells (spread- to FracFocus and compiled by SkyTruth. We provided sheet), updated 13 June 2013. We counted only that list of API numbers, which started in 2011, to those wells with a spud date. The majority of fracking Jim Halvorson, Petroleum Geologist, Montana Board in Louisiana is occurring in the Haynesville shale, per of Oil and Gas, who queried the state’s database for Michael Peikert, Manager, Environmental Section of all produced water reports associated with those Engineering Division at the Department of Natural API numbers in a spreadsheet on 27 June 2013. Resource’s Office of Conservation, personal commu- We summed the produced water figures for the nication, early June 2013. 12-month period ending 31 May 2013. Data on produced water are not available in Louisiana. 32 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level New Mexico North Dakota We calculated the total number of fracking wells in We obtained data on fracking wells in North Dakota New Mexico in two different ways and chose to use from North Dakota Oil and Gas Division, Bakken Hori- the lower estimate to be conservative. zontal Wells by Producing Zone, accessed at www.dmr. We counted 1,353 fracking wells by downloading nd.gov, 29 May 2013. We assumed that all horizontal a list of all permitted wells in the state from New wells are fracked and that all fracking in the state Mexico Energy, Minerals and Natural Resources happens in the Bakken Shale. We obtained data on Department, Oil Conservation Division, OCD Data produced water from this same data source. Howev- and Statistics, 12 June 2013. We selected all wells er, reported production data are cumulative by well with an “H” (for hydraulically fractured) at the end of and we could not calculate production by all fracking the well name, per a conversation with Phillip Goe- wells over a one-year period. Therefore, our tally of tze, New Mexico Oil Conservation Division, 25 June water includes multiple years of production. 2013. We further screened the wells to include just Data on gas production from fracking wells comes those with a status of “Active,” “Plugged” or “Zone from North Dakota Industrial Commission, Depart- Plugged.” We included wells that were identified as ment of Mineral Resources, North Dakota Monthly “New (Not drilled or compl)” if those records other- Gas Production and Sales, accessed at www.dmr. wise contained information suggesting the well has nd.gov/oilgas/stats/Gas1990ToPresent.pdf, 9 August been completed (by listing days in production in 2013. We tallied production in 2012 only. 2011, 2012, or 2013). This count included a few wells started before 2005. Ohio We counted 1,803 fracking wells by reviewing the list For Ohio, we included data for wells drilled in both of hydraulic fracturing fluid disclosure forms submit- the Marcellus and Utica shales from the Ohio Depart- ted by drillers for approval before fracking a well. We ment of Natural Resources, Division of Oil & Gas Re- obtained the list from New Mexico Oil Conservation sources. The state separates shale well permit activity Division, Action Status Permitting Database, 13 June into Marcellus and Utica categories, and presents it in 2013. The requirement to submit these forms began spreadsheets entitled Cumulative Permitting Activ- in 2012, so this count doesn’t include wells from 2011 ity, available at oilandgas.ohiodnr.gov/shale#SHALE, and earlier. This approach was based on a conversa- with well sites permitted through 2 May 2013. tion with Laurie Hewig, Administrative Bureau Chief, New Mexico Oil Conservation Division, 13 June 2013. Produced water and gas information for the Utica came from Ohio Department of Natural Resources, To estimate produced water, we used water produc- Division of Oil & Gas Resources, 2012 Utica Shale tion data reported in New Mexico Energy, Minerals Production Report, 16 May 2013. Data on produc- and Natural Resources Department, Oil Conservation tion from the 11 drilled Marcellus wells came from Division, OCD Data and Statistics, 12 June 2013, and Ohio Department of Natural Resources, Division of filtered as described above. We obtained gas produc- Oil & Gas Resources, Ohio Oil & Gas Well Database, tion figures in the same manner. accessed at http://oilandgas.ohiodnr.gov/well-infor- mation/oil-gas-well-database, 24 June 2013. We used the API numbers from Ohio Department of Natural Resources, Division of Oil & Gas Resources, Marcellus Shale Horizontal Wells, 6 July 2013. Methodology 33 Oklahoma from 2005 through 2009, per Powell Barnett Shale Newsletter, 18 April 2010, as cited in Zhongmin Our count of fracking wells in Oklahoma came from Wang and Alan Krupnick, A Retrospective Review a database downloaded from FracTracker, Oklahoma of Shale Gas Development in the United States, Shale Wells (3-18-2013), accessed at www.fractracker. Resources for the Future, 2013. The Eagle Ford org/downloads/, 28 June 2013. The database does Shale was first drilled in 2008 and by 2009 there not contain any date information. were 107 producing oil and gas wells, per Texas Railroad Commission, Eagle Ford Information, Pennsylvania accessed at www.rrc.state.tx.us/eagleford/, 3 We included data for all unconventional wells with September 2013. spud dates of January 1, 2005 and later from Pennsyl- vania Department of Environmental Protection, Oil • 2010: Nearly 40 percent of wells drilled in 2010 and Gas Reports: SPUD Data Report, www.portal.state. were fracked using more than 100,000 gallons pa.us, 29 May 2013. of water, per Table 7 of Jean-Philippe Nicot, et al., Bureau of Economic Geology, Jackson School Data on gas and water produced in 2012 from Penn- of Geosciences, University of Texas at Austin, for sylvania’s fracking wells came from the Pennsylvania the Texas Water Development Board, Current and Department of Environmental Protection, PA DEP Oil Projected Water Use in the Texas Mining and Oil & Gas Reporting Website—Statewide Data Downloads and Gas Industry, June 2011. We multiplied 39.7 by Reporting Period, accessed at www.paoilandgasre- percent times the 8,133 “new drill dry/comple- porting.state.pa.us/publicreports/Modules/DataEx- tions” in 2010, per Railroad Commission of Texas, ports/DataExports.aspx, 24 June 2013. Our produced Summary of Drilling, Completion and Plugging water tally included “Drilling Fluid Waste,” “Fracing Reports, accessed at www.rrc.state.tx.us/data/drill- Fluid Waste” and “Produced Fluid.” ing/drillingsummary/index.php, 19 July 2013. Tennessee • January 2011 through January 2012: We calcu- lated the number of fracking wells in this period Our estimate of the number of fracking wells came by multiplying the number of wells drilled by from Ron Clendening, Geologist, Oil & Gas Contacts, an estimate of the percentage of those wells Division of Geology, Tennessee Department of the that were fracked. The number of “new drill dry/ Environment and Conservation, personal commu- completions” came from Railroad Commission nication, 8 July 2013. We were unable to obtain an of Texas, Summary of Drilling, Completion and estimate of wastewater or gas production. Plugging Reports, accessed at www.rrc.state. tx.us/data/drilling/drillingsummary/index.php, 3 Texas September 2013. We interpolated between 2010 Texas began keeping track of fracking wells in Febru- and February 2012 using the percentage of wells ary 2012. To compile an estimate of fracking wells that were fracked using the 2010 estimate of 39.7 since 2005, we used several data sources. percent, described above, and the percent fracked from February 2012 to April 2013, described • 2005-2009: We assume that from 2005 through below. 2009, the bulk of fracking activity in Texas occurred in the Barnett Shale and was barely • February 2012 through April 2013: Beginning in beginning elsewhere. A total of 8,746 new February 2012, drilling companies in Texas have horizontal wells were drilled in the Barnett Shale been required to report their drilling activities 34 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level to FracFocus. Per SkyTruth, 19,678 wells were Virginia fracked in Texas in that period that used more than We counted all horizontal wells included in Virginia 100,000 gallons of water. This number of wells Department of Mines, Minerals, and Energy Division equals 82.5 percent of all “new drill dry/comple- of Gas and Oil Information System, Drilling Report, ac- tions” in the same period in Railroad Commis- cessed at www.dmme.virginia.gov, 29 May 2013. sion of Texas, Summary of Drilling, Completion and Plugging Reports, accessed at www.rrc.state. We were unable to obtain data on produced water. tx.us/data/drilling/drillingsummary/index.php, 3 An estimated 15 to 30 percent of water and chemi- September 2013. cals used to frack a well returns to the surface, per Virginia Department of Mines, Minerals, and Energy, Texas does not require reporting of produced water Division of Gas and Oil, Hydraulic Fracturing in Virginia volumes. However, the state does track the volume and the Marcellus Shale Formation, accessed at www. of water that is injected into disposal wells or for dmme.virginia.gov/DGO/HydraulicFracturing.shtml, enhanced recovery in other wells. Our estimate of 12 July 2013. However, we were unable to obtain wastewater is based on the assumption that 99 per- data on how much formation water also is produced. cent of all produced water is reinjected, and there- fore reinjected water volumes indicate wastewater production, per Leslie Savage, P.G., Chief Geologist, West Virginia Oil & Gas Division, Railroad Commission of Texas, Our data for West Virginia includes all permitted wells personal communication, 18 July 2013. Ms. Savage targeting the Marcellus Shale. We were unable to queried the Railroad Commission’s H10 Filing System narrow our count to drilled wells. We also chose to to return results on injected saltwater volumes in include wells without a listed permit date, on the as- 2012, which we used as the basis of our estimate. sumption that any Marcellus drilling in West Virginia This includes both flowback and produced water. has occurred recently. Data is from West Virginia Department of Environmental Protection, Resource Utah Extraction Data Viewer, http://tagis.dep.wv.gov/ fogm/, 20 June 2013. Our count of fracking wells came from the FracFocus database. We screened for wells that reported using We tallied gas production from 2011 (the most recent more than 100,000 gallons of water, and counted year reported). We obtained 2011 production data 1,336 wells. from West Virginia Department of Environmental Pro- tection, Oil and Gas Production Data, accessed from We calculated gas and produced water volumes www.dep.wv.gov/oil-and-gas/databaseinfo/Pages/ from fracking wells in Utah from Utah Department default.aspx, 12 July 2013. We looked up production of Natural Resources, Division of Oil, Gas and Min- from fracking wells by using the API numbers report- ing, Production Data, accessed at http://oilgas.ogm. ed to FracFocus and compiled in SkyTruth’s database. utah.gov/Data_Center/DataCenter.cfm#download, Our calculation of production is an underestimate 12 July 2013. To limit our tally to production from because only 52 wells from FracFocus corresponded fracking wells, we used API numbers for all Utah wells to wells in West Virginia’s production database. included in SkyTruth’s database from FracFocus data. Of the 1,607 wells with APIs in SkyTruth’s database, West Virginia does not collect water production data. we found 2012 production reports for 1,364 wells in Utah’s data. Policy Recommendations 35 Wyoming To estimate water use since 2005, we multiplied aver- age water use per reporting well in each state by the We used data on fracking wells reported to the number of fracking wells (using more than 100,000 FracFocus database to ensure we did not accidentally gallons of water) in each state since 2005. The source include coalbed methane wells. There are 1,126 wells of our well count is described in the previous section. in the FracFocus database that report using more than 100,000 gallons of water. This figure from FracFocus is close to data we ob- Air Pollution tained through another approach. We tallied 1,273 We used data from New York State’s assessment of air horizontal wells since 2005 in Wyoming from Frac- pollution from each well site to estimate the volume Tracker, WY_horiz_06032013, accessed at www. of particulate matter, smog precursors and other haz- fractracker.org/data/, 28 June 2013. FracTracker ardous compounds from fracking. Though the U.S. obtained this list via a request to the Wyoming Oil Environmental Protection Agency recently studied and Gas Conservation Commission. This estimate air pollution from gas drilling, the data were com- excludes any wells that list a spud date before 2005, piled primarily from vertically rather than horizon- and includes wells with no date or that were flagged tally fracked wells and were limited to fewer types of as coalbed. pollutants (see EC/R, Inc., for U.S. Environmental Pro- tection Agency, Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Pro- Water Used duction, Transmission, and Distribution. Background We multiplied the number of fracking wells per state Technical Support Document for Proposed Standards, since 2005 by average water use per well per state July 2011. New York State’s pollution assessment was since 2011. more complete and more relevant to high-volume fracking wells. Average water use per well that reported using more than 100,000 gallons came from Skytruth, Fracking We assume that four wells per drilling site are drilled, Chemical Database, accessed at http://frack.skytruth. fracked and completed each year, per New York State org/fracking-chemical-database/frack-chemical- Department of Environmental Conservation, Revised data-download, 12 June 2013. SkyTruth compiled Draft Supplemental Generic Environmental Impact data posted in PDFs on the FracFocus website into a Statement on the Oil, Gas and Solution Mining Regula- database that includes water use, which can encom- tory Program: Well Permit Issuance for Horizontal Drill- pass freshwater, produced water and/or recycled ing And High-Volume Hydraulic Fracturing to Develop water. The inclusion of recycled water may lead to the Marcellus Shale and Other Low-Permeability Gas some double-counting of water used. We included Reservoirs, 7 September 2011, 6-105. We assumed data beginning in 2011 through the most recent en- that wells produce dry gas, not wet gas, and that tries for 2013. In calculating average water consump- operators flare flowback gas instead of simply vent- tion per well, we excluded wells that listed “None” for ing it. This first assumptions means our air pollution water use. We excluded what appeared to be dupli- estimate may understate the problem, since wet cate entries, based on API numbers, frack date and gas wells have higher emissions, while our second reported water use. We also excluded two wells from assumption changes the mix of pollutants released. Texas that reported using more than 1 billion gallons We multiplied the tons-per-year emissions estimates of water each, which we assumed was a data entry from Table 6.7 of the Revised Draft Supplemental error by the reporting operator. Generic Environmental Impact Statement by a recent year’s well completion figure for each state. 36 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level This emissions estimate does not include the sig- Versus Actual Greenhouse Gas Emissions,” Environ- nificant emissions from ongoing operations, com- mental Research Letters, 7:1-6, 26 November 2012, pressors, and truck traffic to and from drilling sites doi: 10.1088/1748-9326/7/4/044030. This estimate carrying supplies and personnel. is a national average based on nearly 4,000 wells completed in 2010 and assumes 70 percent of wells undergo “green” completions in which fugitive emis- Methane Emissions sions are captured. This likely overstates the green We calculated methane emissions using two differ- completions rate before 2010. ent approaches because neither approach alone pro- vided a complete picture. The lack of data on wells Our estimate has two limitations of note. First, it does drilled, gas produced and emissions per well makes not include methane emissions from pipelines, com- it very hard to assess the extent of global warming pressor stations, and condensate tanks, or carbon damage from fracking. Our first approach multiplied dioxide emissions from equipment used to produce emissions per well during completion by the num- gas. Second, it may not accurately reflect emissions ber of fracking wells. Our second method multiplied from fracked shale wells that produce oil rather than emissions as a percentage of gas produced by the gas. The data we obtained on well completions do amount of gas produced from fracking wells. not distinguish between wells fracked for oil versus gas production and therefore we have chosen to In states with more comprehensive production data, apply this estimate for shale gas wells to all wells. We the energy-based calculation may be more accurate spoke with two experts in the field who believe that, because it is based on state-specific conditions. In given the lack of better data on emissions from oil addition, the energy-based method includes emis- wells, is it reasonable to assume that fracked oil wells sions from a wider range of activities involved in have substantial methane emissions. producing gas from fracking wells—from drilling to fracking to processing—and therefore better reflects We converted methane emissions to carbon dioxide the impact of fracking. equivalents using a 100-year global warming poten- tial of 25 times that of carbon dioxide, per Federal In states where we could obtain no or limited emis- Register, Environmental Protection Agency, 40 CFR Part sions data, the estimate based on per-well emissions 98, 2013 Revisions to the Greenhouse Gas Reporting during completion offers a rough emissions estimate. Rule and Proposed Confidentiality Determinations for The per-well emission factor is conservative because New or Substantially Revised Data Elements; Proposed it is based on a narrower definition of fracking activ- Rule, 78(63): 19802-19877, 2 April 2013. ity (it excludes production and processing). However, it may overestimate emissions from wells that were drilled but produced little to no gas. Emissions Based on Gas Production We calculated methane emissions as a percentage Emissions Based on Well Completion of gas production. See the previous section for a We estimated methane emissions by multiplying an description of how we estimated gas production in estimate of emissions per completion of a fracking each state. gas well by the number of fracking wells in 2012 in We converted cubic feet of gas production to each state. We estimated average emissions of 50,000 megajoules of methane using the assumption that kilograms of methane per well, per Francis O’Sullivan 78.8 percent of gas produced from unconventional and Sergey Paltsev, “Shale Gas Production: Potential wells is methane, per Robert Howarth, et al., “Meth- Policy Recommendations 37 ane and the Greenhouse Gas Footprint of Natural 6.2 to 11.7 percent of production (Anna Karion, et al., Gas from Shale Formations,” Climatic Change 106: “Methane Emissions Estimate from Airborne Mea- 679-690, 2011. (Note that other researchers have surements over a Western United States Natural Gas estimated the methane content of Marcellus Shale Field,” Geophysical Research Letters, 27 August 2013, gas as high as 97.2 percent. See ICF International, doi: 10.1002/grl.50811). Technical Assistance for New York State Department We used a slightly different method to calculate of Environmental Conservation, Draft Supplemental emissions for North Dakota, where a large portion of Generic Environmental Impact Statement on the Oil, gas is flared rather than sold. We calculated emis- Gas and Solution Mining Regulatory Program, as cited sions for the flared gas and emissions for the remain- in Mohan Jiang, et al., “Life Cycle Greenhouse Gas ing gas separately. Because of lack of infrastructure Emissions of Marcellus Shale Gas,” Environmental to get gas to market, 29 percent of all gas produced Research Letters, 6, 034014, July-September 2011, doi:10.1088/1748-9326/6/3/034014, supplemental in North Dakota is flared, per Lynn Helms, North Da- kota Industrial Commission, Department of Mineral materials.) Resources, Director’s Cut, 15 July 2013. We estimated We assume that 3.3 percent of the methane pro- emissions from this gas based on New York State duced over the life of a well is lost as fugitive emis- Department of Environmental Conservation, Revised sions, per Robert Howarth, et al., “Methane and the Draft Supplemental Generic Environmental Impact Greenhouse Gas Footprint of Natural Gas from Shale Statement on the Oil, Gas and Solution Mining Regula- Formations,” Climatic Change 106: 679-690, 2011, as tory Program: Well Permit Issuance for Horizontal Drill- presented in Robert Howarth, et al., Methane Emis- ing And High-Volume Hydraulic Fracturing to Develop sions from Natural Gas Systems; Background Paper the Marcellus Shale and Other Low-Permeability Gas Prepared for National Climate Assessment, 25 February Reservoirs, 7 September 2011, 6-194. We calculated 2012. This estimate includes well-site and process- emissions from the remaining wells using Robert ing emissions from shale and tight-gas sands wells Howarth, et al., “Methane and the Greenhouse Gas that produce gas. The estimate assumes significant Footprint of Natural Gas from Shale Formations,” venting of methane in the initial days after a well is Climatic Change 106: 679-690, 2011, as presented fracked. in Robert Howarth, et al., Methane Emissions from Natural Gas Systems; Background Paper Prepared for The 3.3 percent pollution rate from Howarth, et al., is National Climate Assessment, 25 February 2012. higher than reported in EPA, Inventory of U.S. Green- house Gas Emissions and Sinks: 1990 to 2011, 12 April 2013. However, it is in the range of one recent study Landscape Impacts that measured fugitive emissions over a gas and oil We calculated landscape impacts based on the num- field in Colorado, finding fugitive methane emis- ber of wells in each state. We divided the number sions of 2.3 to 7.7 percent of gas produced (Gabrielle of wells drilled (or permitted, if only that figure was Pétron, et al., “Hydrocarbon Emissions Character- available) since the beginning of 2005 by the aver- ization in the Colorado Front Range: A Pilot Study,” age number of wells per pad to obtain the number Journal of Geophysical Research, 117, D04304, 2012, of well pads. We then multiplied the number of well doi:10.1029/2011JD016360, and Jeff Tollefson, “Air pads by the size of each well pad and the roads and Sampling Reveals High Emissions from Gas Field,” pipelines servicing it. Where possible, we used state- Nature, 483(7384): 139-140, 9 February 2012, doi: specific estimates about the number of wells per pad 10.1038/482139a). A second recent study in the and the acreage damaged by pads and supporting same area measured methane emissions equal to infrastructure. 38 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level For states where most drilling is into the Marcellus Minerals and Natural Resources Department, Oil Con- Shale (Pennsylvania and West Virginia), we as- servation Division, OCD Data and Statistics, 12 June sumed that land disruption patterns are comparable 2013. A small number of 2012 wells appear to be on to those in Pennsylvania, where existing drilling prac- multi-well pads. Given that in neighboring Texas, few tices place an average of 1.8 wells per well pad. Well wells before 2012 were drilled on multi-well pads, pads average 3.1 acres and associated infrastructure we assumed that New Mexico wells average 1.1 wells disturbs 5.7 acres. Pennsylvania data were presented per pad. We assumed pad size for a single-well pad is in New York State Department of Environmental Con- 2.47 acres, based on the average pad size and wells servation, Revised Draft Supplemental Generic Environ- per pad in Weld County, Colorado (see below). We mental Impact Statement on the Oil, Gas and Solution assumed road and pipeline infrastructure occupies Mining Regulatory Program: Well Permit Issuance for 4.75 acres, the same as on public land in western Horizontal Drilling And High-Volume Hydraulic Fractur- Colorado. ing to Develop the Marcellus Shale and Other Low- We made the same assumption for Utah, based on Permeability Gas Reservoirs, 7 September 2011, 6-76. mapping the location of fracking wells and finding We assumed Ohio and Virginia follow the same land few multi-well pads. disturbance patterns. For Colorado, we obtained estimates for acres dam- In Oklahoma, we assumed 1.1 wells per pad, and the aged by wells in Weld County and on public land in same wellpad size and road and pipeline impacts as western Colorado. By looking at the Form 2A docu- in Ohio and Pennsylvania. mentation for 20 fracking wells across Weld County, For Texas, we assumed two wells per pad because we found that an average of 2.25 wells are drilled the sources we consulted suggest that there are per pad and that well pads disturb an average of some multi-well pads but that the number of wells 5.56 acres. We could not obtain an estimate of land per pad remains small. In the Barnett, well pads hold disturbed for roads and pipelines. We obtained this anywhere from one to eight wells, per George King, data from Colorado Oil and Gas Conservation Com- GEK Engineering, Multi-Well Pad Operations for Shale mission, GISOnline, accessed at http://dnrwebmap- Gas Development, Draft Document, 5 May 2010. In gdev.state.co.us/mg2012app/, 11 July 2013. Leases the Eagle Ford Shale, Chesapeake Energy, as of early on federal land in western Colorado average eight 2013, was drilling only half of its wells on multi-well wells per pad, with 7.25 acres of land disturbed per pads, per Jennifer Hiller, “Chesapeake Thinks It Has pad and an additional 4.75 acres for roads and other 342 Million Barrels in Eagle Ford,” Eagle Ford Fix (blog infrastructure, per U.S. Department of the Interior, operated by San Antonio Express-News), 6 May 2013. Bureau of Land Management, Colorado State Office, We assumed pad size is the same as in Pennsylvania Northwest Colorado Office, White River Field Office, (which has an average of 1.8 wells per pad). We as- Draft Resource Management Plan Amendment and sume road and pipeline infrastructure occupies 4.75 Environmental Impact Statement for Oil and Gas De- acres, the same as on public land in western Colo- velopment, August 2012. For our calculation, we used rado. the Weld County data for Weld and Boulder wells, and the western Colorado estimates for Garfield and For New Mexico, we estimated the number of wells Mesa wells. We used the western Colorado estimate per pad after mapping the location of fracking wells of acreage for supporting infrastructure. reported to FracFocus in 2012. We used the API number of those wells to obtain the latitude and For Wyoming, we assumed an average of two wells longitude for each well from New Mexico Energy, per pad. Drilling in the Jonah Field is estimated to Policy Recommendations 39 occur with single well pads and in the Pinedale An- In North Dakota, we assumed one well per pad, ticline with multiple wells per pad, per U.S. Depart- though that estimate may be less valid for wells ment of the Interior, Bureau of Land Management, drilled in the past year, per Mike Ellerd, “Evolution Pinedale Field Office, Proposed Resource Manage- Continues: Densities Could Reach 24 Wells Per Pad; ment Plan and Final Environmental Impact Statement 6,000 Wells Over Next 3 Years,” Petroleum News Bak- for Public Lands Administered by the Bureau of Land ken, 21 April 2013. We assumed the average well Management, Pinedale Field Office, August 2008. From occupies five acres of land, per Alison Ritter, Pub- that same source, we used an estimate of four acres lic Information Specialist, North Dakota Industrial per two-well pad, and 4.9 acres for roads and pipe- Commission Department of Mineral Resources (Oil & lines per pad. Gas Division), personal communication, 8 July 2013. We were unable to obtain a North Dakota-specific In Montana, we calculated land impacts based estimate of acres disturbed for roads, pipelines and on data from current land impacts of wells in the infrastructure and made the assumption that 4.75 HiLine Planning Area in north central Montana. Exist- acres are damaged, the same as in western Colorado. ing wells in the Bowdoin Dome and the rest of the HiLine Planning Area (which may not be high-vol- In Arkansas, we assumed that most of the wells ume wells) disturb an average of 0.21 acres per well drilled to date in Arkansas were drilled one to a pad, pad and 0.67 acres for roads and flow lines, based on per Jeannie Stell, “Angling in the Fayetteville,” Un- a weighted average of data presented in Table 22 of conventional Oil & Gas Center, 15 October 2011. In Dean Stillwell and J. David Chase, U.S. Department the Fayetteville Shale, we assumed well pads are 2.1 of the Interior, Bureau of Land Management, Reason- acres and that associated roads and infrastructure able Foreseeable Development Scenario for Oil and Gas add 2.7 acres, per Dan Arthur and Dave Cornue, ALL Activities on BLM-Managed Lands in the HiLine Plan- Consulting, “Technologies Reduce Pad Size, Waste,” ning Area, Montana, Final Report, 30 October 2012. The American Oil & Gas Reporter, August 2010. We assumed one well per pad. 40 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level Notes 1. U.S. Department of Energy, Energy Information 10. Brian Fontenot, et al., “An Evaluation of Water Administration, Lower 48 States Shale Gas Plays, updated Quality in Private Drinking Water Wells Near Natural Gas 9 May 2011. Extraction Sites in the Barnett Shale Formation,” Environ- mental Science & Technology, 2013, doi: 10.1021/es4011724. 2. Bruce Finley, “Drilling Spills Reaching Colorado Groundwater; State Mulls Test Rules,” Denver Post, 9 11. Joanna Prukop, “Setting the Record Straight on December 2012. Pit Rule,” Farmington Daily Times, 17 September 2008. 3. Laura Legere, “Sunday Times Review of DEP Drill- 12. Nicholas Kusnetz, “A Fracking First in Pennsylva- ing Records Reveals Water Damage, Murky Testing Meth- nia: Cattle Quarantine,” ProPublica, 2 July 2010. ods,” The Times-Tribune (Scranton, Pa.), 19 May 2013. 13. Joaquin Sapien, “With Natural Gas Drilling Boom, 4. New Mexico Oil Conservation Division, Envi- Pennsylvania Faces an Onslaught of Wastewater,” Pro- ronmental Bureau, Generalized Record of Ground Water Publica, 3 October 2009 and Ian Urbina, “Regulation Lax Impact Sites, accessed at www.emnrd.state.nm.us/OCD/ as Gas Wells’ Tainted Water Hits Rivers,” New York Times, documents/rptGeneralizedGWImpact.pdf, 20 September 26 February 2011. 2013. 14. U.S. Environmental Protection Agency, Disinfec- 5. Theo Colborn, et al., “Natural Gas Operations from tion Byproduct Health Effects, 10 April 2009, available at a Public Health Perspective,” Human and Ecological Risk www.epa.gov. Assessment: An International Journal, 17(5): 1039-1056, 15. Public Employees for Environmental Responsi- 2011, doi: 10.1080/10807039.2011.605662. bility, Don’t Drink the Fracking Fluids! Toxic Well Flowback 6. Tom Hayes, Gas Technology Institute, Charac- Pumped for Consumption by Wildlife and Livestock (press terization of Marcellus Shale and Barnett Shale Flowback release), 9 July 2013. Water and Technology Development for Water Reuse, Pow- 16. Abrahm Lustgarten, “Injection Wells: The Poison erpoint presentation, 30 March 2011. Beneath Us,” ProPublica, 21 June 2012. 7. Pennsylvania Department of Environmental 17. Kate Galbraith and Terrence Henry, “As Fracking Protection, DEP Fines Cabot Oil and Gas Corp. $56,650 for Proliferates in Texas, So Do Disposal Wells,” TexasTribune, Susquehanna County Spills (news release), 22 October 29 March 2013. 2009. 18. U.S. Environmental Protection Agency, EXCO 8. Jeff Tollefson, “Gas Drilling Taints Groundwater,” Resources to Pay Penalty for Safe Drinking Water Act Viola- Nature News, 25 June 2013. tions in Clearfield County, Pa. (press release), 12 April 2012. 9. Anthony Ingraffea, Physicians, Scientists and 19. See note 16. Engineers for Healthy Energy, Fluid Migration Mechanisms Due to Faulty Well Design and/or Construction: An Overview 20. Abrahm Lustgarten, “Whiff of Phenol Spells and Recent Experiences in the Pennsylvania Marcellus Play, Trouble,” ProPublica, 21 June 2012. January 2013. Notes 41 21. Jean-Philippe Nicot and Bridget R. Scanlon, 33. Arkansas Department of Environmental Quality, “Water Use for Shale-Gas Production in Texas, U.S.,” Envi- Emissions Inventory and Ambient Air Monitoring of Natural ronmental Science and Technology, 46(6): 3580-3586, 2012, Gas Production in the Fayetteville Shale Region, 22 Novem- doi: 10.1021/es204602t. ber 2011. 22. Kate Galbraith, “Texas Fracking Disclosures to 34. Pennsylvania Department of Environmental Pro- Include Water Totals,” Texas Tribune, 16 January 2012. tection, Northeastern Pennsylvania Marcellus Shale Short- Term Ambient Air Sampling Report, 12 January 2011. 23. Suzanne Goldenberg, “A Texas Tragedy: Plenty of Oil, But No Water,” The Guardian, 11 August 2013. 35. Texas Oil & Gas Accountability Project and Earth- works, Natural Gas Flowback: How the Texas Natural Gas 24. Associated Press, “New Mexico Farmers Selling Boom Affects Health and Safety, April 2011. Water to Oil and Gas Developers,” Albuquerque Journal- News, 30 June 2013. 36. Abrahm Lustgarten and Nicholas Kusnetz, “Sci- ence Lags as Health Problems Emerge Near Gas Fields,” 25. Bruce Finley, “Fracking Bidders Top Farmers at ProPublica, 16 September 2011. Water Auction,” Denver Post, 2 April 2012. 37. Pam Judy, Letter to Murrysville Council, 20 July 2011. 26. U.S. Army Corps of Engineers, Monongahela River Accessed at www.marcellus-shale.us/Pam-Judy.htm. Watershed Initial Watershed Assessment, September 2011. 38. Dozens of stories of residents like Pam Judy 27. Ibid. can be found in List of the Harmed, available at http:// 28. Ibid. pennsylvaniaallianceforcleanwaterandair.files.wordpress. com/2012/05/list-of-the-harmed48.pdf. 29. Don Hopey, “Region’s Gas Deposits Reported to Be Nation’s Largest,” Pittsburgh Post-Gazette, 14 Decem- 39. Don Hopey, “Court Reveals How Shale Drillers, ber 2008; fish kills: Katy Dunlap, Trout Unlimited, Shale Pittsburgh-Area Family Agreed,” Post-Gazette (Pittsburgh, Gas Production and Water Resources in the Eastern United Pa.), 12 August 2013. States: Testimony Before the U.S. Senate Committee on 40. U.S. Occupational Safety and Health Administra- Energy and Natural Resources, Subcommittee on Water and tion, Hazard Alert: Worker Exposure to Silica During Hydraulic Power, 20 October 2011. Fracturing, downloaded from www.osha.gov/dts/hazar- 30. Monika Freyman and Ryan Salmon, Ceres, dalerts/hydraulic_frac_hazard_alert.html, 3 July 2012. Hydraulic Fracturing & Water Stress: Growing Competitive 41. David Brown, Southwest Pennsylvania Envi- Pressures for Water, May 2013. ronmental Health Project, personal communication, 23 31. L.M. McKenzie, et al., “Human Health Risk As- September 2013. sessment of Air Emissions from Development of Uncon- 42. U.S. Environmental Protection Agency, Ozone ventional Natural Gas Resources,” Science of the Total and Your Patients’ Health: Training for Health Care Providers, Environment, 424: 79-87, 1 May 2012. downloaded from www.epa.gov/apti/ozonehealth/key- 32. Shannon Ethridge, Texas Commission on En- points.html#introduction, 11 August 2012. vironmental Quality, Memorandum to Mark R. Vickery 43. Al Armendariz, Emissions from Natural Gas in the Re: Health Effects Review of Barnett Shale Formation Area Barnett Shale Area and Opportunities for Cost-Effective Im- Monitoring Projects, 27 January 2010. provements, prepared for Environmental Defense Fund, 26 January 2009. 42 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level 44. Arkansas Department of Environmental Quality, 52. Robert Howarth, et al., “Venting and Leaking Emissions Inventory and Ambient Air Monitoring of Natural of Methane from Shale Gas Development: Response to Gas Production in the Fayetteville Shale Region, 22 Novem- Cathles, et al.,” Climactic Change, 113(2): 537-539, July ber 2011. 2012. 45. Ian Urbina, “Regulation Lax as Gas Wells’ Tainted 53. Nels Johnson, et al., The Nature Conservancy, Water Hits Rivers,” New York Times, 26 February 2011. Pennsylvania Energy Impacts Assessment, Report 1: Marcel- lus Shale Natural Gas and Wind, 15 November 2010. 46. New York State Department of Environmental Conservation, Revised Draft Supplemental Generic Environ- 54. U.S. Forest Service, Rocky Mountain Region, mental Impact Statement on the Oil, Gas and Solution Min- White River National Forest, 2010 Annual Report, accessed ing Regulatory Program: Well Permit Issuance for Horizontal at www.fs.usda.gov/Internet/FSE_DOCUMENTS/stel- Drilling And High-Volume Hydraulic Fracturing to Develop prdb5304041.pdf, 9 September 2013. the Marcellus Shale and Other Low-Permeability Gas Reser- 55. Sandy Bauers, “Delaware River Basin Commis- voirs, 7 September 2011, 6-175. sion Head Steps Down,” The Inquirer (Philadelphia, Pa.), 14 47. Federal Register, Environmental Protection Agency, September 2013. 40 CFR Part 98, 2013 Revisions to the Greenhouse Gas Re- 56. Amy Mall, Natural Resources Defense Coun- porting Rule and Proposed Confidentiality Determinations cil, Drinking Water for Millions—including D.C.—at Risk for New or Substantially Revised Data Elements; Proposed without Stronger BLM Fracking Rules (blog), 28 November Rule, 78(63): 19802-19877, 2 April 2013. 2012. 48. EPA, Inventory of U.S. Greenhouse Gas Emissions 57. Felicia Fonseca, “N.M. Congressional Delegation and Sinks: 1990 to 2011, 12 April 2013. Seeks Delay in BLM Plan for Otero Mesa,” The Albuquer- 49. David Allen, et al., “Measurements of Methane que Journal, 23 May 2007. Emissions at Natural Gas Production Sites in the United 58. Hall Sawyer, et al., “Winter Habitat Selection of States,” Proceedings of the Natural Academy of Sciences, 16 Mule Deer Before and During Development of a Natural September 2013, doi: 10.1073/pnas.1304880110. Critique Gas Field,” Journal of Wildlife Management, 70(2): 396-403, at Physicians, Scientists and Engineers for Healthy En- 2006. ergy, Gas Industry Study: New EDF and Gas Industry Meth- ane Emission Study Is Not Representative of U.S Natural 59. Hall Sawyer and Ryan Nielson, Western Ecosys- Gas Development, Not the Promised Definitive Study (press tems Technology, Inc., Mule Deer Monitoring in the Pine- release), 16 September 2013. dale Anticline Project Area: 2012 Annual Report, prepared for the Pinedale Anticline Project Office, 11 February 50. Gabrielle Pétron, et al., “Hydrocarbon Emissions 2013. Characterization in the Colorado Front Range: A Pilot Study,” Journal of Geophysical Research, 117, D04304, 60. Wildlife Conservation Society, Natural Gas De- 2012, doi:10.1029/2011JD016360, and Jeff Tollefson, velopment Linked to Wildlife Habitat Loss (news release), 2 “Air Sampling Reveals High Emissions from Gas Field,” May 2012. Nature, 483(7384): 139-140, 9 February 2012, doi: 10.1038/482139a. 61. See note 46, 6-74. 51. Anna Karion, et al., “Methane Emissions Estimate 62. Ibid. from Airborne Measurements over a Western United States Natural Gas Field,” Geophysical Research Letters, 27 August 2013, doi: 10.1002/grl.50811. Notes 43 63. Academy of Natural History of Drexel University, 72. “At least” because the number of undocumented A Preliminary Study on the Impact of Marcellus Shale Drill- wells in Pennsylvania was greater than all of these states ing on Headwaters Streams, downloaded from www.ansp. combined. Source: Interstate Oil and Gas Compact Com- org/research/environmental-research/projects/marcel- mission and U.S. Department of Energy, Protecting Our lus-shale-preliminary-study/, 18 June 2012. Country’s Resources: The States’ Case, undated. 64. Brian M. Dillemuth, Pennsylvania Department of 73. Railroad Commission of Texas, Oil Field Cleanup Environmental Protection, Memorandum to Jack Crook Re: Program, Annual Report – Fiscal Year 2011, 7 February 2012. Frac Water Spill (Range Resources), Unnamed Tributary to 74. Dave Fehling, “Orphans of the Oil Fields: The Cost Brush Run, Hopewell Township, Washington County, Penn- of Abandoned Wells,” StateImpact Texas, 25 April 2012. sylvania, 8 October 2009. 75. Upper Great Plains Transportation Institute, Rural 65. “Waste from Marcellus Shale Drilling in Cross Transportation Safety and Security Center, ND Traffic Creek Park Kills Fish,” Pittsburgh Post-Gazette, 5 June Safety: Oil Counties (issue brief), Summer 2011. 2009. 76. Scott Detrow, “Emergency Services Stretched in 66. Scott Christie, Pennsylvania Department of Pennsylvania’s Top Drilling Counties,” StateImpact Pennsyl- Transportation, Protecting Our Roads, testimony before vania, 11 July 2011. the Pennsylvania House Transportation Committee, 10 June 2010. 77. Abrahm Lustgarten, “Officials in Three States Pin Water Woes on Gas Drilling,” ProPublica, 26 April 2009. 67. Tony Dutzik, Benjamin Davis and Tom Van Heeke, Frontier Group, and John Rumpler, Environment America 78. Charles Choi, “Confirmed: Fracking Practices to Research & Policy Center, Who Pays the Costs of Frack- Blame for Ohio Earthquakes,” NBC News, 4 September ing? Weak Bonding Rules for Oil and Gas Drilling Leave the 2013. Public at Risk, July 2013. 79. Katie M. Keranen et al., “Potentially Induced 68. Headwaters Economics, Fossil Fuel Extraction Earthquakes in Oklahoma, USA: Links Between Wastewa- as a County Economic Development Strategy: Are Energy- ter Injection and the 2011 Mw 5.7 Earthquake Sequence,” Focused Counties Benefiting?, revised 11 July 2009. Geology 41: 699-702, 26 March 2013. doi: 10.1130/G34045.1. 69. Integra Realty Resources, Flower Mound Well 80. Ibid. Site Impact Study, prepared for Town of Flower Mound (Texas), 17 August 2010. 81. W.L. Ellsworth et al., “Are Seismicity Rate Changes in the Midcontinent Natural or Manmade?,” Presentation 70. Texas Water Development Board, Water for Texas: at the Seismological Society of America, 12 April 2012, 2012 State Water Plan, January 2012. abstract available at: http://blogs.agu.org/wildwild- science/2012/04/11/usgs-scientists-dramatic-increase-in- 71. Based on projected water use for production oklahoma-earthquakes-is-man-made/. of oil and gas from shale, tight gas and tight oil forma- tions from Texas Water Development Board, Current and 82. Columbia University, Earth Institute, Wastewater Projected Water Use in the Texas Mining and Oil and Gas Injection Spurred Biggest Earthquake Yet, Says Study. 2011 Industry, June 2011. Oklahoma Temblor Came Amid Increased Manmade Seismic- ity (press release), 26 March 2013. 83. See methodology for data source by state. 44 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level 84. Hollie Deese and Robbie Brown, “University of 97. Denver Water, Supply and Planning: Water Use, Tennessee Wins Approval for Hydraulic Fracturing Plan,” accessed at www.denverwater.org/SupplyPlanning/Wa- New York Times, 15 March 2013. terUse/, 8 July 2013. 85. Associate Press, “Gas Drillers Turn to Northwest 98. Data on water used for fracking came from Georgia,” Chattanooga Times Free Press, 10 March 2013; SkyTruth, Fracking Chemical Database, accessed at http:// and Allison Keefer, Geologist, Environmental Protection frack.skytruth.org/fracking-chemical-database/frack- Division, Georgia Department of Natural Resources, per- chemical-data-download, 12 June 2013. SkyTruth com- sonal communication, 8 July 2013. piled data posted in PDFs on the FracFocus website into a database that includes water use, which can encom- 86. Kevin McDermott, “’Fracking Comes to Illinois pass freshwater, produced water and/or recycled water. Amid a Wave of Money and Controversy,” St. Louis Post- We included data beginning in 2011 through the most Dispatch, 19 June 2013. recent entries for 2013, and included only those wells for 87. See note 46. which water use was listed as 100,000 gallons or greater. 88. See methodology. Truckloads calculated assum- 99. Emissions of hazardous air pollutants will be ing a tanker truck can hold 10,000 gallons of water. higher in regions with wet gas that requires additional processing. The mix of pollutants will be different in 89. Charles Schmidt, “Estimating Wastewater Im- regions that use more venting than flaring, see note 46, pacts from Fracking,” Environmental Health Perspectives 6-105. Also, data from a study conducted by a professor 121: a117-a117, 1 April 2013. at Southern Methodist University on air pollution from fracking operations in the Barnett Shale area of Texas 90. 2009 to 2011: see note 45. suggest that emissions from oil wells are lower than from 91. See note 89. gas wells because of differences in emissions from stor- age tanks. See note 43. 92. James McCarty, “Youngstown Man Admits Dumping Toxic Fracking Waste into Mahoning River,” The 100. Power plant emission data are from 2011: U.S. Plain Dealer (Cleveland, Oh.), 29 August 2013. Energy Information Administration, U.S. Electric Power Industry Estimated Emissions by State, back to 1990 (EIA-767 93. Andrew Maykuth, “Shale Criminal Charges Stun and EIA-906), February 2013. Drilling Industry,” The Inquirer (Philadelphia, Pa.), 13 Sep- tember 2013. 101. Calculated using U.S. Environmental Protection Agency, Greenhouse Gas Equivalencies Calculator, ac- 94. FracFocus, Chemical Use in Hydraulic Fractur- cessed at www.epa.gov/cleanenergy/energy-resources/ ing, accessed at http://fracfocus.org/water-protection/ calculator.html, 9 September 2013. drilling-usage, 23 July 2013. 102. Francis O’Sullivan and Sergey Paltsev, “Shale 95. Minority Staff, Committee on Energy and Com- Gas Production: Potential Versus Actual Greenhouse Gas merce, U.S. House of Representatives, Chemicals Used in Emissions,” Environmental Research Letters, 7:1-6, 26 No- Hydraulic Fracturing, April 2011. vember 2012, doi: 10.1088/1748-9326/7/4/044030. 96. David Manthos, “Cancer Causing Chemicals Used 103. See note 101. in 34 Percent of Reported Fracking Operations,” EcoW- atch, 22 January 2013. 104. Ibid. Notes 45 105. We spoke with two experts in the field who believe that, given the lack of better data on emissions from oil wells, is it reasonable to assume that fracked oil wells have substantial methane emissions. 106. Robert Howarth, et al., “Methane and the Greenhouse Gas Footprint of Natural Gas from Shale Formations,” Climatic Change 106: 679-690, 2011. 107. As presented in Robert Howarth, et al., Methane Emissions from Natural Gas Systems; Background Paper Pre- pared for National Climate Assessment, 25 February 2012. 108. See note 101. 109. See note 53. 110. Colorado Parks & Wildlife, 2013 Factsheet: A Review of Statewide Recreation and Conservation Programs, accessed at http://wildlife.state.co.us/SiteCollectionDoc- uments/DOW/About/Reports/StatewideFactSheet.pdf, 16 July 2013. 111. Growing Greener Coalition, Growing Greener Environmental Stewardship Fund, accessed at http://pa- growinggreener.org/issues/growing-greener/, 16 July 2013. 112. See methodology for explanation of how this was calculated. 113. Natural Resources Defense Council, Spreading Like Wildfire: Oil and Gas Leases Mean that Fracking Could Occur on Tens of Millions of Acres of U.S. Lands, February 2013. 114. U.S. Department of Energy, The Secretary of Energy Advisory Board, Shale Gas Production Subcom- mittee, Second Ninety-Day Report, 18 November 2011. 115. Vinson & Elkins LLP, Hydraulic Fracturing Fluid Disclosure Requirements, 26 October 2012. 46 Fracking by the Numbers: Key Impacts of Dirty Drilling at the State and National Level